DRAFT    GUIDANCE
 -j                 STANDARDS APPLICABLE TO OWNERS AND OPERATORS
o             OF HAZARDOUS WASTE TREATMENT, STORAGE, AND DISPOSAL
^               FACILITIES UNDER RCRA, SUBTITLE C, SECTION 3004
                *Financial Requirements; Interim Status  Standards
                             (40 CFR 265, Subpart H)
              This report (SW-913) was prepared under  contract no.
                     68-01-5794 for the Office of Solid Waste
                                 y 5. Environmental Protection Agency
                                 fteglon 5, Library (PL-12J)
                                 77 West Jackson Boulevard, 12th Floor
                                 Cntcago.il  60604-3590
                       U.S.  ENVIRONMENTAL PROTECTION AGENCY
                                       1981

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                                 PREFACE

     This draft guidance document has been prepared by the International
Research and Technology Corporation.  In preparing this document, we
have sought and incorporated the advice of the Office of Solid Waste,
Environmental Protection Agency (EPA).  The Regional Offices,  the Office
of General Counsel, and the Office of Enforcement have not yet reviewed
this draft guidance document; therefore, this document does not repre-
sent EPA's final views and opinions.

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                                     CONTENTS
LIST OF TABLES	v

1.0   INTRODUCTION	1-1

2.0   BASIC RULES FOR THE CLOSURE COST ESTIMATE	2-1

3.0   BASIC RULES FOR THE POST-CLOSURE COST ESTIMATE	3-1

4.0   PREPARING AND DOCUMENTING THE CLOSURE AND POST-
        CLOSURE COST ESTIMATES	4-1

      4.1   Costs Based upon Experience of the Owner or
              Operator	4-1
      4.2   Contractor Estimates	4-2
      4.3   Cost Estimating Handbooks	4-3
      4.4   Workups from Labor, Material and Equipment
              Requirements	4-4

5.0   ADEQUACY OF THE CLOSURE COST ESTIMATE	5-1

      5.1   Activities Relevant to All Facilities	5-4
            5.1.1   Treating, Disposing or Removing Inventory	5-4
            5.1.2   Decontaminating the Facility	5-6
            5.1.3   Monitoring	5-6
            5.1.4   Professional Engineer Certification	5-6
      5.2   Costs Required Only of Landfills and Surface
              Impoundments	5-7
            5.2.1   Cover	5-7
            5. 2. 2   Vegetation	5-8
            5.2.3   Optional Measures	5-9

6. 0   ADEQUACY OF THE POST-CLOSURE COST ESTIMATE	6-1

      6.1   Inspections and Facility Visits	6-3
      6.2   Reestablishing Cover and Vegetation	6-5
      6.3   Fertilizing	6-5
      6. 4   Mowing	6-5
      6.5   Ground-water Monitoring.	6-6
      6.6   Maintaining and Replacing Fences....	6-6
      6.7   Collecting, Removing and Treating Leachate	6-6

7.0   REVISING THE CLOSURE AND POST-CLOSURE COST ESTIMATES	7-1
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8.0   ADJUSTING THE COST ESTIMATES TO ACCOUNT FOR INFLATION	8-1

9.0   SAMPLE COST ESTIMATES	9-1

      9.1   Introduction	9-1
      9.2   Example - Surface  Impoundments	9-2
      9.3   Example - Land Treatment Facilities	9-31
      9.4   Example - Landfills	9-56
      9.5   Example- Incinerators	9-75
      9.6   Example - Multiple Process Facility  With  Tanks
                      and Surface  Impoundments	9-91
      9.7   Example- Post-Closure Cost Estimates	9-114
                                  iv

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                             LIST OF TABLES

Table                                                              Page

5-1   CLOSURE COST ESTIMATE RAPID CHECKS	5-3

6-1   COSTS OF SELECTED POST-CLOSURE ACTIVITIES	6-4

8-1   HYPOTHETICAL SAMPLE PAGE OF SURVEY OF CURRENT
        BUSINESS	8-3

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                           1.0  INTRODUCTION

     EPA has developed standards for financial requirements for owners
or operators of hazardous waste facilities as part of the Interim Status
Standards — Subpart H Financial Requirements.  This guidance document
covers only those portions of Subpart H promulgated on 19 May 1980 and
the technical amendments to those regulations.  These portions require
the owner or operator to prepare cost estimates for closure and post-
closure.  At later dates, Subpart H will also contain final regulations
covering liability requirements and financial assurance mechanisms.

     The purpose of the cost estimation requirements is to determine
the amount of financial assurance needed.  These requirements are pre-
sented in 40 CFR §265.142 for closure and 40 CFR §265.144 for post-
closure.  Each of these sections contains a requirement for a written
cost estimate available on the premises (40 CFR §265.142(a) and 40 CFR
§265.144(a)), a requirement for revisions in the cost estimate whenever
changes are made in the applicable plans (40 CFR §265.142(b) and 40
CFR §265.144(b)) and a requirement for annual adjustments in the closure
and post-closure cost est.tmates to reflect inflation (40 CFR §265.142(c)
and 40 CFR §265.144(c)) .  All owners or operators of hazardous waste
facilities, except those facilities owned or operated by states and the
federal government, must prepare closure cost estimates.  All owners or
operators of facilities in which hazardous wastes will remain after
closure, except those facilities owned or operated by states and the
federal government, must prepare a post-closure cost estimate.  The
closure cost estimates must be available on the premises on the effective
date of these regulations, i.e., November 19, 1980, for those facilities
not required to have a post-closure plan.  Owners or operators of land
disposal facilities, or facilities closed as such, will not be required
to have their closure and post-closure cost estimates available until
six months from the effective date of these regulations, i.e., May 19,
1981, because of the complexities involved in developing plans and
estimates for these types of facilities.
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     The purpose of this document is to assist the Regional Offices in.
implementing those sections of the interim status regulations relevant
to closure and post-closure cost estimates.  Since the bases for the
cost estimates are the closure and post-closure plans, this section
should be read in association with the guidance for closure and post-
closure plans.  The remainder of this document is divided into eight
sections:  basic rules for the closure cost estimate; basic rules for
the post-closure cost estimate; preparing and documenting the closure
and post-closure cost estimates; adequacy of the closure cost estimate;
adequacy of the post-closure cost estimate; revising the closure and
post-closure cost estimates; adjusting the cost estimates to account
for inflation; and sample cost estimates for various types of facilities,
The emphasis throughout this document is upon interim status.  This is
particularly important to the sections on adequacy of cost estimates,
which are designed for rapid review and inspection.

     Sample cost  estimates have  been developed  for  several kinds  of
facilities in  the  final section  of this document.   The purpose of  these
samples  is to  illustrate  the concepts  involved  in  closure and  post-
closure  cost estimates and the  formats which might  be appropriate.  The
samples  are developed  through  a  series of  worksheets  designed  to  illus-
trate an appropriate  format for  demonstrating the  scope  and nature of
the  activities involved arid the  key  unit  cost elements used  in arriving
at the final estimate.  Closure  and  post-closure costs will be highly
site-specific, and as  a result,  these  worksheets should  be viewed  as
only general guidance  and are  unlikely to  be applicable  in any specific
case.  In  no  case should  the unit  costs  used  in the samples  be regarded
as proper  and  accurate costs to  be used  in developing cost estimates.
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             2.0  BASIC RULES FOR THE CLOSURE COST ESTIMATE

     In developing closure cost estimates for interim status, the
following concepts should be used for guidance.

2.1  The closure cost estimate is based upon the methods described
     in the closure plan.

     A cost estimate should be prepared for each activity or sub-activity
listed in the closure plan.  The cost estimate is based upon the ac-
tivities, quantities and methods indicated in the closure plan.  For
example, a cost estimate should be prepared for treating, disposing or
removing inventory.  It must account for managing the maximum inventory
expected as indicated in the closure plan.  The method used for treating,
disposing or removing the inventory would be identical to that indicated
in the closure plan.  For example, if the closure plan indicates managing
1000 tons of waste, of which 800 tons are to be disposed or treated
on-site and 200 tons removed to an off-site TSDF, the cost estimate
must include estimates for these respective costs.

2.2  "The estimate must equal the cost of closure at the point in the
     facility's operating life when the extent and manner of its opera-
     tion would make closure the most expensive, as indicated by its
     closure plan."*

     The goal of the cost estimate is to ensure that if at any point in
time a facility had to begin closure for reasons unrelated to a catas-
trophe at the site, the costs of the closure would not exceed the cost
estimate.  Thus, the conditions on which the cost estimate is predicated
will probably differ significantly from anticipated conditions at the end
of normal facility life with respect to amounts of undisposed or un-
treated wastes on-hand, status of processing equipment, and area of the
facility in disturbed condition.
*EPA Interim Status Standards, 40 CFR §265.142(a)

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     For example, for purposes of the cost estimate, the estimate of
maximum inventory on-site should include the maximum normally expected
on-site.  This estimate should take account of any long-term cycle of
inventory on-hand, and should take account of predictable events which
may occur over the life of the facility, such as adverse weather condi-
tions preventing normal activity at a landfill and "down time" to
periodically rebrick the refractory of an incinerator.  The initial
estimate need not, however, include provisions for highly unusual
contingencies unless they exist at the time the facility submits its
initial cost estimate.  For example, the cost estimate need not include
provision for such unusual contingencies as the effects of the 50-year
storm or the failure of a liner in a major trench calling for removal of
all waste in that trench.  If such events occur over the life of the
facility and cause the original maximum inventory estimate to be
exceeded, the owner or operator should revise the closure plan to
reflect the current situation unless he can immediately correct the
situation so that his original estimate of maximum inventory is not
exceeded.  In cases of doubt, the Regional Administrator's office should
be contacted as to the advisability of revising the cost estimate.  In
no case, however, should the initial cost estimate list a maximum inven-
tory less than that actually on-site.  If normal operating procedures
include steps which would reduce closure costs, such as dredging of an
impoundment or capping portions of a landfill, it should be assumed that
closure will occur just before these activities.  Thus, in the closure
cost estimate all costs associated with such procedures should be
included.  This assumption is to ensure adequate funds in the closure
cost estimate for the situation of forced closure due to an unforeseen
event such as business failure of the facility's owner or operator.

    If experience shows that the initial cost estimate over- or under-
estimated the most expensive conditions likely to occur over the life
of the facility, or if those conditions are no longer possible, then
revisions may be made in the cost estimate as appropriate (see Section
7.0).  For example, if late in the life of the facility the total
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disturbed area is only 10 acres but had exceeded  20  acres  earlier,  it
would be appropriate to revise the cost estimate  downward.

2.3  Cost estimates are to be based upon  the operating costs  to  the
     owner or operator of carrying out the  planned activities.

     This means that in developing the cost estimate the owner's or
operator's depreciation costs, capital recovery factors, and  interest  on
debt need not be included as part of the  costs.   For example, capital
recovery and depreciation factors for earth-moving equipment  owned  by
the owner or operator and costs of land already owned need not be
considered as part of the costs of disposing of inventory  at  a landfill.
If equipment must be rented to complete closure activities, however, the
costs of this rental must be part of the  cost  estimate.  If the  owner  or
operator plans to contract out a specific activity (e.g.,  sandblasting
and steam-cleaning the equipment on-site, planting vegetation),  the full
costs of that contract would be the correct cost  estimate.

2.4  The cost estimates should include all  associated costs necessary  to
     carry out closure procedures.

     A cost estimate for a given activity must include all costs asso-
ciated with this activity, including fully  loaded labor costs (i.e.,
including fringe benefits and overhead),  any costs of supervision,  fuel
and maintenance costs for the equipment used, administrative costs, and
provisions for normal contingencies.  Administrative costs include  all
costs associated  with taxes and insurance, as well  as costs of  routine
administration,  paperwork and reporting.   "Provisions for normal contin-
gencies" means that the  cost estimates should include a factor for
unforeseen events that may increase costs, such as those routinely  put
into most initial cost estimates.   Such contingencies include adverse
weather and other unanticipated complications.  Given the absence in the
closure plan of  detailed engineering designs, the uncertain nature of
precise facility conditions at the time of closure,  and the lack of
provision for inflation  during the closure period (which, in some cases,
can be quite lengthy), the provision for  contingencies should be

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generous.  Standard engineering practice shows that in most cases
a provision for contingencies could reasonably be expected to fall
within the range of 15 to 25 percent.  The lower end of the range
is appropriate for smaller facilities which require a short closure
period and have fewer uncertain variables.  The higher end of the
range accounts for larger facilities which may require extensive
activities and a longer closure period, for which unusual weather
conditions or uncertain decontamination needs could seriously affect
the cost of closure.

    A cost estimate for treating inventory in an incinerator would
include fully loaded labor costs, supervision, maintenance, utilities,
any chemicals and catalysts employed, administration, and provisions
for contingencies.  Although the cost estimate should include all of
these cost elements, they need not be documented separately.  Thus, fox-
example, well documented unit costs for treating inventory are
appropriate even if they do not include separate documentation for
maintenance, utilities, or all energy costs.  This point is further
discussed in Section 4.0 and examples of an appropriate approach
are shown in Section 9.0.

2.5 The cost estimates should be based upon costs in the year in which
    the estimate is prepared; there is no need to provide for inflation
    in developing the cost estimate, as this will be provided for in
    the adjustment procedure.

    Costs should be based upon current costs.  For practical purposes,
this means costs within one year of the time of preparation of the cost
estimate.  There is no need to adjust data or cost estimates based
upon data within the current year to the exact month for which the
cost estimate is dated.
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          3.0  BASIC RULES FOR THE POST-CLOSURE COST ESTIMATE

     In developing a post-closure cost estimate for interim status, the
following concepts should be used for guidance.

3.1  A post-closure cost estimate must be prepared for all facilities
     at which hazardous wastes remain on-site after closure.

     Post-closure cost estimates are required for landfills and surface
impoundments and land treatment systems at which any hazardous wastes
remain on-site following final closure.  If an owner or operator of
a surface impoundment originally plans to close it as a storage or
treatment facility by removing all hazardous waste, but later decides to
close it as a disposal facility, he must immediately prepare a post-closure
plan for the facility.  In similar fashion, if the owner or operator of a
land treatment facility originally prepares a closure plan based on the
assumption that treatment will render the waste non-hazardous but tests
show this is not the case, he must immediately prepare a post-closure
plan and cost estimate.

3.2  The post-closure cost estimate is based upon the methods described
     in the post-closure plan.

     The post-closure cost estimate is based upon the activities, quan-
tities, and methods indicated in the post-closure plan.  A cost estimate
should be prepared for each activity or sub-activity listed in the post-
closure plan.  For example, a cost estimate should be prepared to cover
maintenance activities.  It must reflect the methods to be used in the
post-closure plan and the rates of fertilization, mowing, sprinkling,
and other activities listed in the post-closure plan.

3.3  The post-closure cost estimate should be prepared for the entire
     area expected to contain hazardous waste at the time of final
     closure.
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     The post-closure estimate should provide for post-closure care for
the entire facility as it is expected to exist at the time of final
closure.  Thus, if a 180-acre facility is expected to be filled at a
rate of 10 acres per year, the initial post-closure cost estimate must
reflect the costs of post-closure care for the full 180 acres.

3.4  The post-closure cost estimate should reflect the costs of
     purchasing all necessary labor, materials and equipment to carry
     out post-closure requirements.  Unlike the closure cost estimate,
     it may not be assumed that the owner or operator already has
     adequate equipment for the purpose.

     It is highly uncertain whether the entire period of post-closure
care will be carried out by the owner or operator himself, and whether
on-site labor and equipment will be available.  Therefore, the cost esti-
mate should assume that all services required for post-closure must be
contracted for in order to ensure financial adequacy.  The post-closure
cost estimate must therefore include adequate allowance for profits on
the post-closure care services.  For example, if regular mowing is part
of the post-closure plan, the costs must reflect the costs of hiring a
service to carry out this mowing, rather than the cost of having a laborer
of the owner or operator using mowing equipment already in use elsewhere
by the owner or operator.  Similarly, monitoring costs must be estimated
assuming it is necessary to hire outside help both to take the necessary
samples and to conduct the necessary laboratory tests.

3.5  The post-closure cost estimate must be complete and include all
     associated costs necessary to carry out post-closure procedures.

     A cost estimate for a given activity must include all costs asso-
ciated with this activity, including fully loaded labor costs, any costs
of supervision, fuel and maintenance costs for equipment used, adminis-
trative costs, and provisions for normal contingencies.  Administrative
costs include all costs associated with taxes and insurance, as well
as costs of routine administration, paperwork and reporting.  "Provisions
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for normal contingencies" means  that  the cost estimates should include a
factor for unforeseen events  that may increase costs, such as those
routinely put into most initial cost  estimates.  Such contingencies
include adverse weather and other unanticipated complications.  Given
the absence in the post-closure plan  of detailed engineering designs,
the uncertain nature of precise facility conditions at the time of post-
closure, and the uncertainty of the kinds of maintenance to be required
during the post-closure period, the provision for contingencies should
be generous.  Standard engineering practice shows that the provision
for contingencies could reasonably be expected to fall within the
range of 15 to 25 percent.  As with closure costs, the documentation
for the cost estimate need not break  out all of these headings
separately; they must, however, be included in any unit or activity
cost estimates (see Sections 4.0 and  9.0).  It is particularly important
in the case of post-closure care to include supervision and inspection
requirements that normally might be neglected in the cost estimate.
Since labor may no longer be readily available on-site, such routine
functions as facility inspection and supervision and review of work
must be explicitly included.

3.6  The post-closure cost estimate covers the period beginning at the
     completion of closure of the facility and lasts for 30 years there-
     after.

     The post-closure cost estimate does not cover the cost of main-
taining any partially closed  portions of the facility during facility
life.  However, the fact that partial closure has occurred for portions
of the facility does not in any way shorten the period of post-closure
care required for the purposes of the post-closure cost estimates.  The
post-closure period begins with the professional engineer's certifica-
tion of adequate closure.  As a result, provision should be made for any
normal remedial measures early in the post-closure period, suck as
significant portions of the vegetation failing to develop adequately.

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3.7  Post-closure expenditures can be expected to occur in two cate-
     gories;  regular annual expenditures and expenditures that occur
     with less than annual frequency.  The written estimate of the
     annual cost of post-closure monitoring and maintenance is equal to
     the sum of regular annual expenditures plus the expected number of
     non-annual expenditures times their costs.

     This can be written as the following formula:
where P is the annual post-closure cost estimate, A is the size of
expenditures occurring annually, F^ is the number of times over 30 year;
non-annual expenditure i is expected to occur, and N^ is the cost of
non-annual expenditure i.  There may, of course, be several kinds of
annual expenditures and several kinds of non-annual expenditures.
Specific types of non-annual expenditures that need to be considered
include provisions for special activities resulting from unusual
weather, replacement of equipment, and provisions for replanting and
other similar activities in the two to five years following closure.
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                    4.0  PREPARING AND DOCUMENTING THE
                 CLOSURE AND POST-CLOSURE COST ESTIMATES

     Although written closure and post-closure cost  estimates  are
required, the regulation does not specify format or  documentation suit-
able for this cost estimate.  As a result,  the ultimate  requirements  in
this area will be up to the discretion of the Regional Administrator.
Certain general guidance may, however, prove useful.  The  cost estimate
must ultimately contain at least enough detail so that the Regional
Office can make a reasonable evaluation of  its validity  at the time
of inspections during interim status.

     The overall goal of the cost estimate  and its documentation is to
provide an estimate of the costs and the documentation necessary
to demonstrate the reasonableness of the estimate.   It is not
required that the cost estimate have the kind of detail  and accuracy
appropriate to a contractor preparing a bid for a job.   There is little
need for a highly polished cost estimate since these cost  estimates are
for a hypothetical task that is to take place in the rather distant
future.

     Four basic approaches which might be used in developing costs for
the activities listed in the closure plan are:

     •  Costs based upon experience of the  owner or  operator
     •  Contractor estimates
     •  Cost estimation handbooks
     •  Workups from labor, material and equipment requirements

4.1  COSTS BASED UPON EXPERIENCE OF THE OWNER OR OPERATOR

     The most directly relevant source of cost information, in many
cases, will be the experience of the owner  or operator in  operating the
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facility.  An example would be the costs of treating or disposing of
inventory on-site, which will normally be a simple continuation of the
normal operating practice's of the business.  In the simplest case, cost
of treating or disposing of inventory may be computed as the annual
operating costs divided by the fraction of a year required for adequately
treating or disposing of inventory.  Such an estimate could then be
documented by the past year's accounts, the amount of material treated
or disposed over that year, and evidence that the year had involved
relatively typical activities (e.g., if, for a landfill, no trench
had to be dug or covered over the course of the year, then the year
might not be considered a suitable example from the viewpoint of
assuming the most expensive closure conditions likely to occur over the
life of the facility).  Given that the requirement that a cost estimate
be available on-site is either six or twelve months after notification
of the cost estimation requirement, a variety of closure activities could
be documented from noting'the costs of the activity as they occur over
the interim period.*  For example, for a landfill, the costs and activities
involved in partial closures could be documented and used as a base for
unit cost estimates of the cost of final cover.

     Similarly, costs of monitoring tests during post-closure will be
similar to the costs of monitoring tests during facility life, though
gathering samples will be more expensive due to the need to assume
purchased labor and travel to the facility.  Possibly the best source
for costs and frequency of many kinds of post-closure non-routine
expenditures is the actual experience in maintaining currently partially
closed portions of a landfill.

4.2  CONTRACTOR ESTIMATES

     A variety of costs, particularly if services are to be purchased
from a contractor or contractors by the owner or operator, may be
*As discussed in Section 1.0, owners or operators of land disposal
facilities are not required to have their cost estimates available
until twelve months after the effective date of these regulations.
Owners or operators of other facility types must have an estimate
available within six months of the effective date of these regulations
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obtained from contractor estimates.  For example, an owner or operator
could ascertain the costs of certification by an independent professional
engineer by asking several professional engineers for estimates of the
costs of certifying the completion of activities listed in the closure
plan.  If an owner or operator plans to send either inventory or con-
taminated residues to an off-site TSDF, inquiries to ascertain distances,
hauling costs, and treatment or disposal costs would be in order.  It is
not necessary for purposes of documenting, to have written and validated
cost estimates.  Adequate documentation could note who was contacted
and their approximate estimates.

4.3  COST ESTIMATING HANDBOOKS

     There are a variety of commercial engineering cost estimation manuals
that provide guides to equipment and labor needs and unit costs of
specific operations that may be relevant to various activities associated
with closing hazardous waste facilities.  Such manuals may be reasonably
used as a source for cost estimates for closure costs.  Care must be
taken in using such manuals.  They vary widely with respect to whether
or not unit costs cited include such factors as administration, normal
contingencies, profits, and whether or not allowances must be made to
adjust theoretical work rates to normal field conditions.

     From the owner's or operator's view, care should be taken that an
overestimate is not produced by using estimates which allow for profits
and capital recovery on equipment when this is not required if he is using
his own equipment for closure.  Distinct underestimates are possible if
attention is not given to the indicated need.for adjustment of theore-
tical work rates to normal field conditions and for administrative costs.
As a result, suitable documentation for a cost estimate for an activity
based upon such a handbook would be a copy of the relevant pages of the
handbook, including those pages providing instructions as to the use of
the unit cost estimates and any adjustments from the cited costs used in
arriving at the unit cost estimate employed in the cost estimate itself.
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4.4  WORKUPS FROM LABOR, MATERIAL AND EQUIPMENT REQUIREMENTS

     In some cases, there may be no way to arrive at a useful cost
estimate other than by a detailed workup of the costs.  Such a workup
would include an estimate of the labor, equipment, energy and material
needs for the activity to be estimated, the basis for these assumptions,
and the total time required for the activity.  Allowance would then
need to be made for supervision and administrative costs and any
necessary adjustments for fully loaded labor and equipment costs.
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               5.0  ADEQUACY OF THE  CLOSURE  COST  ESTIMATE

     For the closure cost estimate to be  judged adequate,  it  must  meet
the following criteria:

     1.  The closure cost estimate must contain cost  estimates  for all
activities presented in the closure  plan.  The cost estimate  must  also
reflect the quantities and methods associated with all  of  the activities
presented in the closure plan.  (Note that the adequacy of  the  cost
estimate is therefore dependent on the adequacy of the  closure  plan.)

     2.  The closure cost estimate must be documented in order  that the
bases for the cost estimate can be checked.

     3.  The resulting cost estimate must reflect the actual  costs of
carrying out closure.  This can be determined by  a check of the sources
listed for documentation providing that Rule 2 has been met.  A cross-
check can be made by using alternative sources, i.e., if the  owner's or
operator's cost estimate is based upon a contractor estimate, this may
be checked through reference to a cost estimation manual,  experience of
other owners or operators, or inquiries to other  contractors.

     The cost estimate must be available upon the premises  for  inspec-
tion during interim status.  As a result, it will be useful to  have
available simple and rapid checks as to the adequacy of the cost esti-
mate.  The remainder of this discussion is devoted, in  part,  to a  discus-
sion of simple checks that could be  accomplished  in less than an hour or
two with the aid of the closure plan and a visit  to the facility to deter-
mine the adequacy of the closure plan (see Section 12.Oof  the  draft
guidance for Subpart G, Closure and  Post-Closure  Care).  These  checks
are not intended for use by owners or operators and may not be  used as a
method for developing a cost estimate.
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     If an initial check raises questions as to the adequacy of the cost
estimate, several steps may be taken.  First, a copy of the complete
cost estimate may be required and reviewed, and a check made of the
documentation.  It is quite possible that the cost estimate could be
accurate and fall outside the ranges indicated in the discussion below.
If, after review, the cost estimate still seems inadequate, the owner or
operator could be specifically requested to make the desired alterations.
If this approach fails to result in a satisfactory cost estimate, there
are two possible recourses during interim status.  The Regional Adminis-
trator could bring an enforcement case or he could request part B of the
permit application and thus revise the cost estimate as part of the permit
application process.

     Unfortunately, the annual report of the facility, though it must
include the cost estimate, does not contain adequate information to
determine the accuracy of the cost estimate.  For example, the amount
of inventory on-hand is not a required element of the permit application.
Therefore, in order to check on the accuracy of the cost estimate, it
may be necessary to visit the facility.  An inspector could then obtain
copies of the closure plan and cost estimate, and conduct a quick review
of the key variables for the closure plan, as discussed in Section 12.0
of the draft guidance for Subpart G, Closure and Post-Closure Care.

     Table 5-1 shows the key elements involved in verifying the closure
cost estimate, listed by major types of activity involved.  For each
activity, the major elements required to check the adequacy are the
activity indicator (the variable that determines the degree of the
activity, e.g., quantity of inventory, volume of contaminated soil),
unit costs (estimates of the unit costs for each activity of the facility
in question), and sources for variation in unit costs from facility to
facility.  Also included in this table are current typical costs of each
required activity.  A relatively wide range is used due to variations
depending upon the region and upon the nature of the wastes (e.g., high
hazard wastes have greater costs than lower hazard wastes).  As these
costs are national averages, more accurate estimates would be obtained

                                   5-2

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using average costs for the specific area.  These costs also must be
adjusted annually for inflation.  A mechanism for making this inflation
adjustment is discussed in Section 8.0.

     For example, to check the adequacy of the cost estimate of treating
or disposing of inventory, one would:

     (1)   Determine  the  adequacy of the estimated amount of inventory
          (this  could  most readily be done by  examining the closure plan
          and facility conditions to determine whether the closure plan
          adequately reflects  inventory needs  of  the facility);
     (2)   Determine  whether, in the case of treatment facilities  (including
          incinerators),  provision has been made  for treating,  disposing,
          or  removing  residues off-site which  result from treating inventory;
     (3)   Multiply the quantity of inventory in the  closure plan  by the
          unit costs given in  the Table; and
     (4)   Consult the  variability factors listed  in  the Table (e.g.,
          throughput,  type of  facility, nature of waste,  on- or off-site
          disposal), to  determine whether the  facility should be  at the:
          high or low  end of the range for unit costs.

5.1  ACTIVITIES SZLEVANT TO ALL FACILITIES

5.1.1  Treating, Disposing, or Removing Inventory

     For facilities  not  engaged in disposal requiring post-closure care
(all types of facilities except landfills, and surface impoundments and
land treatment facilities in which hazardous wastes  remain after closure),
treating, disposing  or removing inventory will frequently be the largest
single cost element.  The exceptions to this rule of thumb will normally
be situations in which unusual decontamination problems occur,  such as
large amounts of waste water accumulating at the facility.  The key unit
parameters in determining the  costs of treating,  disposing or removing
inventory to an off-site TSDF  are the amount of inventory on-hand and,
for incineration and processes involving treatment,  the relationships
                                   5-4

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between inventory processes and residues to be disposed of or treated
on-site or removed to an off-site TSDF.  The quantity of inventory on-
hand will vary enormously depending on the type of facility, the annual
throughput of the facility, and management practices.  For some types of
facilities, inventory can be minimal.  For example, some landfills accept
only trucked-in wastes on a space-available basis.  For such a landfill,
there would very seldom be any inventory at all.  It is also possible,
however, that start-up problems or, in the case of landfills, failure of
                           i
a major cell or cells could lead to a situation in which there is an
enormous amount of inventory which cannot be quickly worked off, and this
would have to be accounted for in the cost estimate.

     The unit costs of removing inventory are dependent upon whether the
inventory is to be disposed of or treated on-site or removed to an off-
site TSDF.  In the vast majority of cases at disposal facilities, the
disposing or treating of inventory will take place on-site.  If disposal
or treatment takes place on-site, the unit costs can be expected to
fall between 30 and 80 percent of the prevalent Regional costs for
removing the inventory to an off-site TSDF.  On-site costs will be less
than off-site costs because closure costs need only include the immediate
operating costs of disposing or treating inventory and not factors for
capital recovery, land, etc.  The variation will depend upon the type of
facility, its normal throughput (because of economies of scale, small
facilities will have higher unit costs than large facilities for almost
all types of facilities) , the quality and safety of disposal practices
at the facility, and the nature of the wastes.  For a landfill which always
maintains adequate open trench capacity, inventory disposal costs could
be a very small fraction of normal off-site landfill disposal costs.  This
is because the costs of building the trench would not need to be included,
and the costs of cover and vegetation are covered separately.  Under these
circumstances, costs for treating or disposing of inventory could
be lower than the 30 percent indicated.  For inventory or residue that
must be removed to an off-site TSDF, unit costs will be 100 percent of
normal off-site costs in the Region, plus appropriate hauling costs.
                                   5-5

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5.1.2  Decent«™-
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5.2  COSTS REQUIRED ONLY OF LANDFILLS AND SURFACE IMPOUNDMENTS

5.2.1  Cover

     Some form of cover will usually be required for both landfills and
surface impoundments which have hazardous wastes remaining after
closure.  Cover and the associated vegetation (see Section 5.2.2) will
normally be the dominating element in determining the costs of closure
for a landfill or surface impoundment.

     The materials to be used will depend on the types of soil available
on-site as well as the conditions of the facility.'  Since purchasing
soil off-site is costl/, it is likely that most owners or operators
will use soil available on-site, if at all possible, for the final cover,
i.e., the layer with low permeability and the layer capable of supporting
vegetation, if applicable.  It is possible to improve the quality of
available soil by blending various soils, using soil additives, or making
other provisions which would provide equivalent protection.  For example,
soil blending and synthetic additives may decrease the permeability of
the on-site soil as well as make certain soils more capable of supporting
vegetation.  In addition to improving the quality of available soil,
the Agency anticipates that many owners or operators will use membrane
liners protected above and below by buffer soil layers instead of com-
pacted clay for the layer of the cover with low permeability.  These
membrane liners may be cost effective if adequate on-site soil material
is unavailable or an acceptable degree of compaction is not possible at
a particular facility, given the wastes disposed or facility conditions.

     When clay is used as a liner material, the key activity indicators
are acres not yet covered and the depth of the cover.   As noted in the
closure plan, decisions as to the depth of the cover and the adequacy of
on-site materials are dependent on engineering judgment and are not
covered in this guidance document.  The costs associated with such cover
may vary from $500 to $1500 per foot per acre of cover.  The key sources
of variation are:
                                   5-7

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     (1)  The amount and nature of terracing to be used in the cover;
     (2)  The depth of the area to be filled in the case of surface
          impoundments;
     (3)  The nature of the cover, including whether or not treatment
          is required to achieve proper degrees of impermeability; and
     (4)  The design of the cover.

     For synthetic liners, the key activity indicator is the acres not:
covered.  The costs associated with, such covers vary "widely, depending
on the type of material chosen and the thickness needed to ensure adequate
low permeability.  It is not the purpose of this document to assess
alternative materials or to provide guidance as to the level of per-
meability which is acceptable.  The costs associated with installed
liner material per acre vary from $5,000 to $20,000 per acre.  The key
sources of variation are:

     (1)  The amount and nature of terracing to be used in the cover;
     (2)  Type of liner material chosen; and
     (3)  Thickness of material necessary to achieve desired degree  of
          permeability.

5.2.2  Vegetation

     For most facilities, some vegetation will be required in order  to
stabilize the cover and prevent erosion problems.  The key activity
indicators are the number of acres in need of vegetation (which may  include
areas previously seeded but for which vegetation has not properly
developed) and the type of vegetation to be employed.  Unit costs can
be expected to range from $400 to $1,500 per acre.  The lower end of
the range would represent the costs of minimum fertilization and planting
with no provision for reseeding and replanting of any kind.  The maximum
costs would represent the costs of providing a lawn-type cover.  Other
key variables in determining cost of vegetation are:
                                   5-8

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      (1)  The type of soil  (including determining  the degree of
          fertilizer required); and
      (2)  The type of seed  used.

Establishing complete vegetation within the 90 days to six months over
which closure will normally take place cannot be attained.  As a result,
some costs associated with  developing and establishing vegetation will
probably take place early in the post-closure period.  Therefore, the
adequacy of the closure plan with respect to vegetation should be checked
in coordination with an examination of the provisions for maintaining
vegetation in the early years  of the post-closure  plan.

5.2.3  Optional Measures

    Three kinds of optional measures, bearing significant costs, may be
necessary at some facilities:  collection, removing and treating leachate;
collecting gas; and additional measures required to protect human health
and the environment.  Even  for facilities with leachate collection systems,
the cost of leachate collection, removal, treatment and disposal for
closure will normally be the relatively minor cost of occasionally
collecting the leachate and hauling it away to an  off-site TSDF.  In
certain rare cases, leachate build-up may be great enough to require
an extensive on-site treatment and disposal system.  If this is the
case, this could be a significant cost during the  closure period.
Maintaining an existing gas collection system normally will be a rela-
tively minor cost.  At certain facilities, additional activities may
be required to ensure the protection of human health or the environment,
such as those discussed in  Section 9.0 of the draft guidance for Subp*art G.
Such measures could be extremely expensive and would constitute a large
share of closure costs; however, the exact combination of necessary
measures will be extremely  site-specific.
                                  5-9

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             6.0  ADEQUACY OF THE POST-CLOSURE COST ESTIMATE

     For the post-closure cost estimate to be judged adequate, it must
meet the following criteria:

     1.  The post-closure cost estimate must contain cost estimates for
all activities presented in the post-closure plan.  The cost estimate
must also reflect the quantities and methods associated with all of the
activities,presented in the post-closure plan.  (Note that the adequacy
of the cost estimate is therefore dependent on the adequacy of the post-
closure plan.)

     2.  The post-closure cost estimate must be documented  so  that the
bases  for the cost estimate  can be  checked.  Documentation  may be
performed in a variety of ways; however, it must  be provided in such
a way  that the sources can be reviewed and judged by an outside party.
For example, if an owner  or  operator states that  a cost estimate was
taken  from an engineering cost estimation manual,  the estimate could
be easily verified.

     3.  The resulting cost  estimate must reflect  the actual costs of
carrying out post-closure activities.  This can be determined  by a check
of the sources listed for documentation providing  that Rule 2  has been
met.   A cross-check can be made by  using alternative sources,  i.e., if
the owner's or operator's cost estimate is based  upon a contractor
estimate, this may be checked through reference to a cost estimation
manual, experience of other  owners  or operators,  or inquiries  to other
contractors.

     The cost estimate must  be available on the premises for inspection
during interim status.  As a  result, it will be useful to have available
simple and rapid checks as to the adequacy of the  cost estimate.  The
remainder of this  section is devoted to a discussion of simple checks
of the costs of specific activities that could be  used with the aid of
the closure plan and a visit  to the facility to determine the  adequacy
of the post-closure plan  (see Section  12.0 of the  draft guidance for

                                   6-1

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Subpart G, Closure and Post-Closure Care).  These checks are not
intended for use by owners and operators and may not be used as a method
for developing a cost estimate.

     If an initial check raises questions as to the adequacy of the cost
estimate, several steps may be taken.  First, a copy of the complete
cost estimate may be requested and reviewed, and a check made of the
documentation.  It is quite possible that the cost estimate could be
accurate and fall outside the ranges indicated in the discussion below.
If, after review, the cost estimate still seems inadequate, the owner or
operator could be specifically requested to make the desired altera-
tions.  If this approach fails to result in a satisfactory cost estimate,
there are two possible recourses during interim status.  If the cost
estimate is obviously completely inadequate, the Regional Administrator
may start an enforcement action or he may request part B of the permit
application and revise the cost estimate as part of the permit applica-
tion process.

     Unfortunately, the annual report of the facility, though it must
include the cost estimate, does not contain adequate information to
determine the accuracy of the cost estimate.  Therefore, in order to
check on the adequacy of the cost estimate, it may be necessary to visit:
the facility.  An inspector could then obtain copies of the post-closure
plan and cost estimate and conduct a quick review of the key variables
for the post-closure plan, as discussed in Section 12.0 of the draft
guidance for Subpart G, Closure and Post-Closure Care.

     Table 6-1 shows the costs of certain activities which may be asso-
ciated with post-closure cost estimates.  This is a list of selected
major activities, and is not intended to reflect all possible post-
closure activities.  These activities have been broken down by key cost
elements rather than by elements of the post-closure plan.  For example,
one heading in Table 6-1 is "Inspections and Facility Visits."  The table
simply shows the expected costs of such visits per hour on-site.  Deter-
mining the number of inspections and facility visits required will be
                                   6-2

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highly site-specific and will depend upon the post-closure plan.  Further,
these inspections and facility visits may serve a variety of purposes in
the post-closure plan.  For example, inspections and facility visits may
be for the purpose of ensuring adequate erosion control, maintaining
surveyed benchmarks, obtaining ground-water monitoring samples, or check-
ing the adequacy of leachate collection facilities.

     Table 6-1, for each activity indicated, shows an estimate of unit
costs and notes the sources of variation in these unit costs.  The unit
costs are given in 1980 dollars.  In order to maintain the accuracy of
Table 6-1, it should be updated on an annual basis to reflect inflation.
A discussion of the methods for adjusting the cast .estimates to account
for inflation is provided in Section 8.0.  The sources of variation in
unit costs are specific to the headings listed.  Two generic sources of
variation, however, have not been noted.  First, all costs can be
expected to vary regionally and locally.  Ideally, these national esti-
mates of unit costs should be replaced by costs developed from experience
for the region or state in which the facility is located.  Second, all
costs will vary with the remoteness of the facility.  Since most post-
closure activities are relatively small in scale and may involve only
a few days on-site, significant travel time to and from the facility
will have a noticeable effect on almost all costs.

6.1  INSPECTIONS AND FACILITY VISITS

     As noted above, inspections and facility visits may be needed for a
variety of purposes.  The unit costs given will thus be relevant in
checking the costs of a variety of activities.  The estimated unit costs
in 1980 dollars are $20 to $100 per hour on-site.  The chief source of
variation in these unit costs will be the professional level of the
personnel involved.  It will normally be useful to have an inspection or
facility visit by a professional engineer at least once a year.  Inspections
and facility visits by less technically qualified personnel will depend upon
the specifics of the post-closure plan, the climate, and the size and
nature of the facility.
                                   6-3

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                               TABLE 6-1

               COSTS OF SELECTED POST-CLOSURE ACTIVITIES
     ACTIVITY
UNIT COSTS*
SOURCE OF VARIATION
   IN UNIT COSTS**
  1. Inspection/Facility
     Visits

  2. Reestablishing
     Cover and Vegetation
  3.  Fertilizing
  4.  Mowing

  5.  Groundrwater
     Monitoring

  6.  Maintaining and
     Replacing Fences

  7.  Collecting, Removing
     and Treating Leachate
$20-100/hr. on-site
$300-1500/acre
$50-200/acre


$10-30/acre

$200-600/well


$.20-.80/ft./yr.


$.20-.80/gallon
Professional level
of personnel

Amount of erosion
Nature of cover
Type of soil
Amount & density
  of seed

Amount of fertilizer
Method of spreading
Monitoring plan
requirements

Type of fence
Climate

Chemical composition
  1980 dollars.
**
  All costs of all activities vary by region and with the remoteness
  of the facility.
                                 6-4

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6.2  REESTABLISHING COVER AND VEGETATION

     Reestablishing cover and vegetation may be necessary for a variety
of purposes, including:

     •  Replanting to establish vegetation not adequately established
        during closure;
     •  Replanting to repair minor erosion or rodent control
        problems ;
     •  Reestablishing cover lost as a result of a major contin-
        gency, such as a major storm or flood; and
     •  Reestablishing cover to correct for subsidence problems.

     The costs of this activity in 1980 dollars may range from $300 to
$1,500 per acre.  This cost will vary according to the nature of the
cover, the type of soil used, and the amount and density of seed.  In
addition, the costs can be expected to vary according to the amount of
erosion or subsidence which necessitates replacing the topsoil or cover
material.  The lowest costs are for simple replanting, and the highest
are for reestablishing and compacting as well as reseeding substantial
portions of the clay cover and topsoil.

6.3  FERTILIZING

     Depending upon the vegetation, topsoil employed, and climate, some
fertilization may be necessary.  The frequency will be highly variable.
The estimated range of costs for this activity is $50 to $200 per acre
with the variation dependent upon the amount of fertilizer and the
method of spreading it.

6.4  MOWING

     Mowing is necessary in any climate in which deep rooted vegetation
may readily be established.  In most cases, it will be the most cost
effective means of preventing such deep rooted vegetation.  In some

                                   6-5

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climates, mowing requirements may be minimal or there may be more cost
effective methods than mowing for ensuring that deep rooted vegetation
does not become established.  The estimated range of costs in 1980
dollars is $10 to $30 per acre.

6.5  GROUND-WATER MONITORING

     At all facilities, a ground-water monitoring program of some kind
will be required.  In addition to the costs of associated site visits
to gather samples, these costs will be based on the average costs of
the tests required, which are the result of the monitoring plan require-
ments .
6.6  MAINTAINING AND REPLACING FENCES

     Many facilities will be required to have some kind of fence as
security during the post-closure period.  Assuming the use of some type
of chain link fence, provision will need to be made for replacing the
fence at least once over the 30-year post-closure period.  In addition,
some provision must be made for inspecting and maintaining the fence.
It is estimated that the cost of such maintenance and replacement will
be $.20 to $.80 per linear foot of fence per year.  The variation is
dependent upon the type of fence used and the severity of the climate.

6.7  COLLECTING, REMOVING, AND TREATING LEACHATE

     At some facilities, a system for collecting, removing, and treating
leachate may be required during post-closure.  The estimate given here is
based on the assumption that a small amount of leachate will be collected
periodically and removed to an off-site TSDF.  The costs of an extensive
leachate collection system requiring treatment on-site would normally be
much higher.  The estimated range in costs is from $.20 to $.80 per
gallon of leachate removed, with the range in the costs depending in part
upon the chemical composition of the leachate.
                                   6-6

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     7.0   REVISING THE CLOSURE AND POST-CLOSURE COST ESTIMATES

     The closure and post-closure cost estimates must be revised when-
ever a change in the closure or post-closure plan is made that affects
the costs of closure or post-closure care.  Changes to closure and post-
closure plans are discussed in Sections 11.1 and 11.2 of the guidance
for Subpart G of the Interim Status standards.  Changes in the closure
plan which may cause a revision in the closure cost estimate include:

     •  Change in facility size and/or capacity;
     •  Changes in technology that may affect treatment and disposal or
        decontamination techniques, type of cover chosen, etc.;
     •  Changes in the closure schedule which alter the length of
        the closure period by greater than one month (e.g., severe
        weather conditions may halt construction activities and
        extend the closure period by more than one month);
     •  Changes in the schedule of periodic activities which
        affect activities required at closure (e.g., failure to
        partially close a. facility would mean that a larger area
        than previously estimated would need to be closed at
        closure; the closure plan must always account for the
        maximum extent of the operation open at any time over the
        life of the facility);
     •  Changes in types and/or quantities of wastes that affect
        activities required at closure (e.g., the type and/or
        quantity of waste on-site at closure will affect the
        choices of treatment and disposal; for example, the amount
        of waste removed to an off-site TSDF by the owner or operator of
        an incinerator depends on the types and quantities of resid-
        uals that remain after burning the wastes.   The
        types and quantities of waste can also affect monitoring
        requirements and cover requirements);
                                7-1

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     •  Change in maximum quantity of inventory ever expected on-
        site;
     •  Change in cover requirements from what was originally
        proposed;
     •  Changes in ground-water monitoring requirements as a result
        of an owner's or operator's operating experience or new data
        which was not available when the plan was written.  The ground--
        water monitoring regulations stipulate that all or part of the
        requirements may be waived if there is a low potential for
        pollution (§265.90).  Revisions will also be likely when the
        EPA provides more guidance and technical engineering data on
        the kinds of monitoring appropriate for hazardous waste facil-
        ities; and
     •  Operating contingencies during closure which may affect closure
        requirements (e.g., inclement weather causes construction
        problems; more contaminated soil needs to be disposed
        at closure than anticipated as a result of problems occurring
        during operation).

     Changes in the post-closure plan which may cause a revision in the
post-closure cost estimate include:

     •  Change in facility size which will affect the extent of
        maintenance required;
     •  Changes in monitoring requirements as a result of an
        owner's or operator's operating experience, new data which was not
        available when the plan was written or modifications approved by
        the Regional Administrator (e.g., changes in the number of wells
        monitored and samples, the frequency of analyses, types of
        analyses required).  During the 30-year post-closure
        period, the owner or operator may petition the Regional
        Administrator to discontinue or alter the monitoring
        requirements; alternatively, under certain circumstances,

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the Regional Administrator may require an owner or operator
to continue monitoring beyond 30 years.  Revisions will also
be likely when the EPA provides more guidance and technical
engineering data on the kinds of monitoring appropriate
during post-closure;
Changes in annual routine maintenance, including changes
in the nature and frequency of the activities required
(e.g., a more extensive erosion control program may be
required than originally anticipated);
Changes in activities required on an intermittent basis
or changes in the frequency of these activities (e.g., an
accelerated replanting schedule or more frequent replace-
ment of wells than anticipated);
Operating contingencies which occur during the life of the
facility or post-closure which a'ffect post-closure ac-
tivities (e.g., severe weather conditions affecting acti-
vities required for erosion control, cover maintenance,
or maintenance of diversion structures);
Changes in surrounding land use (e.g., if the population
density increased, the measures needed to maintain
facility security might change; ground-water monitoring
program might be affected);
Changes in monitoring and maintenance technology; and
Modifications approved by the Regional Administrator; the
owner or operator may petition the Regional Administrator
to allow some or all of the requirements for post-closure
to be discontinued or altered before the post-closure period
is ended; any such changes can only be made after the
post-closure period begins and would constitute a revision
to the post-closure plan made during post-closure.
                          7-3

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     Revisions may be desirable that either raise or lower  the closure
and post-closure cost estimates.  For example, the closure  cost estimate
may need to be revised and increased if partial closure schedules are
not met or if there is unexpected accumulation of inventory due to
temporary problems at the facility.  It is quite possible,  however, that
the cost estimate may need to be revised downward.  A facility may have
very large inventory due to temporary start-up problems at  the time the
cost estimate is first developed which is later reduced to  a more normal
inventory. In such a situation, revising the closure cost estimate
downward would be reasonable.  It is also possible, given the rapid
development in some types of hazardous waste disposal, that new technol-
ogies may offer much less expensive means of carrying out certain
activities than are now envisioned.  This would also be a legitimate
cause for revisions of the plan and cost estimate.
                                   7-4

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                    8.0  ADJUSTING THE COST ESTIMATES
                           TO ACCOUNT FOR INFLATION

     Subpart H of the Interim Status Standards requires that both the
closure and post-closure cost estimates be adjusted annually for infla-
tion.  This adjustment is to take place on the anniversary of the
effective date of the regulations, November 19, 1980.  Although owners
or operators of land disposal facilities are not required to have
estimates available until May 1981 (six months from the effective date
of these regulations), all owners or operators are required to adjust
their estimates beginning in November 1981 and annually thereafter.
Adjustments of the post-closure cost estimate for inflation need not
take place once the facility is closed.

     Data for calculating the inflation adjustment factor must be ob-
tained from the "...annual Implicit Price Deflator for Gross National
Product as published by the U.S. Department of Commerce."*  This price
deflator is published in the Survey of Current Business, a U.S. Depart-
ment of Commerce, Bureau of Economic Analysis, publication, and in
Economic Indicators, a Council of Economic Advisors publication.  These
documents are published monthly and subscriptions may be obtained from
Superintendent of Documents, U.S. Government Printing Office,
Washington, D.C., 20402.  This information also may be obtained by
calling the Bureau of Economic Analysis, U.S. Department of Commerce.

     The GNP price deflator was chosen as an appropriate inflation index
and is more accurate than the more readily available Consumer Price
Index and Wholesale Price Index.  However, it is not as widely published
as the other two indices.  Thus, the typical hazardous waste facility
owner or operator, in the normal course of his business, will not have
data on the implicit price deflator for GNP or copies of the Survey of
Current Business or Economic Indicators.  Copies of these publications
*EPA Interim Status Standards, 40 CFR §265.142(c)
                                   8-1

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also may not be readily available in small libraries to which the
owner or operator might have easy access.  As a result, the EPA
Regional personnel must have available the most recent editions of
the Survey of Current Business or Economic Indicators and provide the
necessary adjustment factor to owners or operators who telephone or
write for this information.

     Table 8-1 shows a sample of the section in the Survey of Current
Business in which the GNP implicit price deflator may be found.  The
table is constructed to show how this section might appear on 19 Novem-
ber 1981, the "first anniversary of the effective date of the regula-
tion."  The numbers shown are hypothetical, as this guidance document is
being written in May 1980.  The implicit price deflator to be used is
the first for which numbers appear, i.e., the one labeled Gross National
Product as underlined in Table 8-1.  The note "Index, 1972=100" may be
ignored.  The method of calculating the inflation adjustment factor
required by the regulation makes the index year chosen and changes in
the index year irrelevant.  The regulation states:

     "The inflation factor must be calculated by dividing the
     latest published annual Deflator by the Deflator for the
     previous year."*

GNP deflators are normally developed both quarterly and annually.  The
regulation requires the use of the deflator listed in the column headed
"annual totals."  The quarterly data should be ignored entirely.  The
calculation of the inflation adjustment factor should use, for the
latest published annual implicit price deflator, the deflator for 1980
(circled in the chart).  The deflator for the previous year will then be
EPA Interim Status Standards, 40 CFR §265.142(c).
                                    8-2

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 the deflator  for  1979  (also circled  in  the  chart).*  Using  the example

 provided,  the inflation adjustment factor is  then calculated  as the

 annual  implicit GNP deflator  for  1980 divided by the annual implicit  GNP
 deflator for  1979, as  follows:

                                  175.13
                                  165.50

resulting  in an  inflation adjustment  factor of  1.058.  This  number  is

then multiplied  by the last cost  estimate to obtain  the new  current cost

estimate.  These numbers are hypothetical and do not represent  actual

1981 data; they  are presented solely  to illustrate how to use the Survey

of Current Business to make the necessary calculation.
*The GNP implicit price deflator for a given year may be subject to
revision.  If the figure cited in a previous issue is different from
the figure cited for the same quarter in the current issue, the owner
or operator should use the current figure.  If the owner or operator
is requesting this information by telephone, he should ask for the GNP
implicit price deflator for the previous year and for the year prior
to the previous year.
                                   8-4

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                       9.0  SAMPLE COST ESTIMATES

9.1  INTRODUCTION

     This section provides samples of cost estimates for closure of
surface impoundments, land treatment facilities, landfills, inciner-
ators, and a multiple process facility with tanks and small surface
impoundments.  A sample post-closure cost estimate for landfills is also
provided.  The purpose of these sample cost estimates is to illustrate
the concepts involved in a proper cost estimate and suitable formats
which might be employed.  However, neither the cost estimates in total
nor the unit costs are designed to be applicable to any specific
facility.  Neither the total costs nor the unit costs used in
these cost estimates should be considered targets when the owner or
operator prepares his own cost estimate.

     The cost estimates are prepared in the form of a series of work-
sheets.  This was considered the simplest mechanism for providing a
careful, easily checked cost estimate.  In the sample cost estimates
given, each worksheet is accompanied by an explanation of each item on
the worksheet.  These explanations are designed to help indicate how the
worksheet was developed.  Explanations of this type would not be appro-
priate in the cost estimate prepared by the owner or operator.  Instead,
the owner or operator would include, for each item in the cost estimate,
reference to the appropriate section of the closure or post-closure plan
as applicable, and any necessary documentation as to the accuracy of
specific unit costs.
                                9-1

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9.2                  EXAMPLE - SURFACE IMPOUNDMENTS

     Sludge from an industrial wastewater treatment plant is pumped to
a four-acre surface impoundment for stabilization.  It is assumed that
at the time of closure, the contents of the impoundment will measure a
depth of 3 feet; this material will be 90 percent water and 10 percent
solid sludges.  The total depth of the impoundment will be 5 feet
(allowing 2 feet of freeboard above the surface of the liquids).   It
is further assumed that all necessary equipment required to complete
closure will have to be rented, as none is available on-site (the
costs of equipment rental and manpower will be factored into the unit
cost estimates for various operations).  The costs of closure are
developed for two options: 1) completely disposing of wastes on-site,
and 2) removing all hazardous materials from the facility prior to  *
closure.
                                   9-2

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              SAMPLE CLOSURE COST ESTIMATING WORKSHEETS:
         SURFACE IMPOUNDMENTS IN WHICH WASTES REMAIN AT CLOSURE

A.   Removing Free Liquid and Decontaminating the Facility
     In this case, it is assumed that free liquids can be removed by
evaporation.  Alternative possibilities that might be necessary and would
result in somewhat different cost estimates are the transporting of free
liquids to an off-site TSDF and the disposing of free liquids into surface
waters after suitable treatment, either through a treatment facility already
in place or a package treatment facility.  For this example, all contam-
inated soil is disposed of in the impoundment; therefore, no additional
costs are associated with decontaminating the soil.
      1.  Method used:  As noted above, the method used for removing the
free liquid is evaporation.
      2.  Time required to evaporate liquid:  The calculations to justify
this time would be taken from the closure plan.  It is assumed that 70 days
would be required for evaporation of free liquids.
      3.  Cost of routine operations per day:  This includes the cost of
inspecting the facility required once a week and any minor maintenance
work that would need to be done as a result of these inspections.
      4.  Cost of maintenance during evaporation (Line 2 x Line 3):  Cost
of routine operations at $10 per day times 70 days results in a total cost
of maintenance of $700.
      5.  Volume of remaining sludge:  The volume of the remaining sludge
is given as 1936 cu. yds. based on the initial assumption that the liquid
in the pond is 10 percent sludge.
      6.  Source of sorbent materials:  In this case, the sludge is to be
solidified and buried on-site in the surface impoundment.  As a. result,
sorbent materials are needed. • It is assumed, for the example, that sorbent
materials must be purchased off-site.
      7.  Cost of sorbent materials:  Assume that sorbent materials (e.g.,
cement kiln dusts) are needed on a one-to-one ratio to the sludge and must
be purchased with a delivered cost of $3.25 per cu. yd.  The total cost
is $6,292.
      8.  Unit cost of mixing and stabilization:  The unit cost of mixing
sorbent material with sludge is assumed to be $1.60 per cu. yd.
                                   9-3

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       9.   Cost of  mixing and stabilization:   This is calculated as 1936 cu.
  yds.  of  sludge plus  1936 cu.  yds.  of sorbent material,  for a total of 3872
  cu. yds.   This is multiplied  times $1.60 per cu.  yd.,  to  give a total cost
  of  $6,195.

     10. Total cost of removing  free liquids  and  sludge  stabilization
 (Line  4 +  Line 7 + Line  9)::  The sum of  the above  costs  is  $13,187.
     11. Decontaminate equipment:   The assumed costs  for decontaminating
.equipment  is  $500.
     12. Decontaminate and flush any pumps or liquid  lines:   The assumed
 costs  for  decontaminating equipment is $2000.
     13. Disposing or treating residues  from  decontamination:   Assume that
 the  costs  for disposing  or treating liquids and residues from the above
 decontamination processes is $1000.
     14. Total costs  of  all  activities on Worksheet A (Line  10 4- Line 11 +
 Line 12 +  Line 13):   The sum of  these activities  is  $16,687.

 B.     Placing Final Cap
     1.  Area to be capped:  The area directly requiring a  cap is 4 acres
 (19,360 sq. yds.)  In addition,  it  is assumed that an additional acre of
 land area  (4840 sq. yds.) surrounding the impoundment,  containing dikes,
 etc.,  will require vegetation  and,  therefore,  must undergo  some prepara-
 tion.
     2.  Required  impermeable  material:   It is assumed  that  25,813 cu.  yds.
 of impermeable material  will be  required (19,360  sq.  yds. x 4 ft. depth).
     3.  Source of impermeable material:  It  is assumed  that suitable
 impermeable material  can be  obtained through  bulldozing  dikes and other
 appurtenances on-site.
     4.  Cost of material:  Since the material is  available on-site, there
 will be no cost.
     5.  Required  topsoil:  At the sample facility,  it is  assumed that 2  feet
 of  the topsoil will be required  in order to ensure adequate cover so that
 roots  of  the  vegetation  will not penetrate the cap.   It  is,  therefore,
 assumed that  16,133 cu.  yds. of  topsoil  (24,200 sq.  yds. x 2/3 yd. depth)
 will be required.
     6.   Source of topsoil:   In  this case,  it is  assumed that topsoil is
 available  on-site  at  a relatively short  haul.
                                    9-4

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      7.   Cost of topsoil:  Since the topsoil is available on-site, there
 will be  no cost.
      8.   Cost per cubic yard for hauling, compacting and grading:
It is assumed in this case that the unit cost of those services is
$1.60.
      9.   Cost of placing impermeable portion of cap (Line 2 x Line
8):   The result of these assumptions is that the cost of the cap
in place (with suitable grading) is $41,301.
      10.  Cost of placing topsoil (Line 5 x Line 8):  The cost of
placing the topsoil, given the above assumptions, is $25,813.
      11.  Total cost of cap (Line 4 + Line 7 + Line 9 + Line 10):
Summing the above elements, the total cost for the capping operation
is $67,114.

C.    Planting Final Vegetation
      1.   Area to be vegetated:  The area to be vegetated is assumed to
be 5 acres.
      2.   Type of vegetation to be used:  The closure plan specifies that
coarse field grass (a mixture of rye grasses and Kentucky fescue) will
be employed for final vegetation.
      3.   Quantity of seed per acre:  Based on discussions with facility
operators, we assume that 150 pounds of seed will be used per acre.
      4.   Cost of seed per pound:  Calls to local suppliers determined
that seed is available at $.50 per pound.
      5.   Total cost of seed (Line 1 x Line 3 x Line 4):  Given the
above assumptions, the total cost of seed will be $375.
      6.   Type of fertilizer to be used:  Given the topsoil and
climatic conditions at the sample site, 10/10/10 fertilizer is
assumed to be adequate.
      7.   Quantity of fertilizer per acre:  Discussions with local
suppliers indicated that .25 tons per acre would be a reasonable
fertilizer application rate.
      8.   Cost of fertilizer per ton:  Calls to local suppliers determined
that fertilizer is available for $200 per ton.
      9.   Total cost of fertilizer (Line 1 x Line 7 x Line 8):  Given
the above assumptions, the total cost of fertilizer will be $250.
                                    9-5

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      10.  Cost of soil preparation per acre:  Soil preparation, including
both disking and fertilizing, .is assumed to be $135 per acre (including
equipment rental costs).,
      11.  Total cost of preparing soil (Line 1 x Line 10):  The total cost
of preparing soil (excluding materials) is assumed to be $675.
      12.  Cost per acre for seeding:  It is assumed that seeding the
sample site will cost $200 per acre (including equipment rental costs).
      13.  Total cost of seeding (Line 1 x Line 12):  The total cost of
seeding (excluding materials) is assumed to be $1000.
      14.  Cost per acre of mulching:  The cost per acre of purchasing
and applying a hay mulch is assumed to be $140.
      15.  Total cost of mulching (Line 1 x Line 14):  The total costs of
mulching (including the costs of hay) are assumed to be $700.
      16.  Total costs for vegetation (sum of Lines 5,  9, 11, 13, and 15):
Total costs for establishing vegetation are $2950.

D.  Ground-water Monitoring
      Assume that closure of the surface impoundment will require a total
of 90 days.  In order to determine the maximum possible ground-water
monitoring costs, the most extensive monitoring needed at closure is
assumed.  Assuming that ground-water quality analyses are required
annually and ground-water contamination analyses are required semi-
annually, the most expensive case is that in which both sets of analyses
are required during the 90-day closure period.
      1.  Number of wells monitored:  For the sample surface impoundment,
it is assumed that six wells would need to be monitored.
      2.  Number of samples per well:  One sample is taken per well for
both analyses.
      3.  Total number of samples (Line 1 x Line 2):  Given the above
assumptions, six samples are required.
      4.  Number of hours required for collecting the sample:  It is
assumed that experience has shown that two hours are sufficient to gather
samples from each well.
      5.  Total number of hours required for collecting the samples
(Line 3 x Line 4):  For six samples, 12 hours would be required for
collecting the samples.
                                   9-6

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      6.  Number of hours required for preparing and delivering the sample:
It is assumed for the example that this can be done in two hours.
      7.  Person-hour costs for collecting samples:  Assume that the fully-
loaded costs for labor required for sample collection, preparation and
delivery averages $15 per hour.
      8.  Total sample and collection costs ((Line 5 + Line 6) x Line 7):
This results in total sampling and collection costs of $210.
      9.  Number of ground-water quality analyses:  One analysis must
be made for each well sample, for a total of six.
      10.  Number of ground-water contamination analyses:  One analysis
must be made for each well sample, for a total of six.
      11.  Unit cost of ground-water quality analysis:  It is assumed
that the cost of an analysis for the following parameters is $77 per
sample:
                         Chloride - $6.00 per sample
                         Iron - $12.00 per sample
                         Manganese - $12.00 per sample
                         Phenols - $25.00 per sample
                         Sodium - $12.00 per sample
                         Sulfate - $10.00 per sample
      12.  Unit cost of ground-water contamination analyses:  It is
assumed that the cost of an analysis for the following parameters is
$108 per sample:
                         pH - $4.00 per sample
                         Specific Conductance - $4.00 per sample
                         Total Organic Carbon - $25.00 per sample
                         Total Organic Halogen - $75.00 per sample

      13.  Total ground-water quality analysis costs (Line 9 x Line 11):
For six samples at $77 per analysis, this yields a total cost of $462.
      14.  Total ground-water contamination analysis costs (Line 10 x
Line 12):  For six samples at $108 per analysis, this yields a total
cost of $648.
      15.  Total analyses costs (Line 13 + Line 14):  The total analyses
costs, therefore, are $1,110.
                                   9-7

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      16.  Number of technical hours for administration:  This includes all
time necessary to administer and report the data from the analysis and is
estimated as eight hours.
      17.  Person-hour technical costs:  The fully-loaded cost required
for this work is assumed to be $30 per hour.
      18.  Total technical costs for administration (Line 16 x Line 17):
Given the above assumptions, total costs for administering the tests are
assumed to be $240.
      19.  Number of clerical hours:  Assume for this case that five hours
of clerical time are required to produce the necessary reports.
      20.  Person-hour clerical costs:  Assume the fully-loaded costs for
clerical work are $8 per hour.
      21.  Total clerical costs (Line 19 x Line 20):  Given the above
assumptions, the total clerical costs are $40.
      22.  Total administrative costs (Line 18 + Line 21):  The sum of
technical and clerical costs are then $280.
      23.  Monitoring equipment maintenance:  It is assumed that an
average of $150 is required for a 90-day period to ensure adequate
maintenance of monitoring equipment and wells.
      24.  Total monitoring costs (Sum of Lines 8, 15, 22, and 23):
Total monitoring costs, excluding administration and contingencies, are
then $1750.

E.  Fence Maintenance
      In this case, it is assumed that the area to be enclosed is 5 acres
(24,200 sq. yd.).  Assuming that the site is square, each side is 156
yards.  The perimeter of the site is then 624 yards.
      1.  Length of fence to be replaced:  Since this facility is to retain
hazardous compounds, the integrity of its security fence is important.
Our estimate is that 10% of the existing perimeter security fence will
have to be replaced due to wear and corrosion.
      2.  Unit cost of replacing fence:  The security fence is a galvanized
6-foot high chain link fence made of #9 wire.  The installed unit cost
of replacement sections is $13.06 per linear foot.
                                   9-8

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      3.  Total cost of replacing fence (Line 1 x Line 2):
The cost of replacing the damaged fence sections is the product of the
length of fencing needing replacement and the unit cost of replacing
the fence, for a total of $2429.

F.    Professional Certification
      1.  Number of person-hours required for inspections:  It is assumed
that 80 hours are required for periodically inspecting all aspects of
closure of the surface impoundment.
      2.  Cost per person-hour:  In this case, assume that a registered
independent professional engineer may be hired at a cost of $75 per hour.
      3.  Total costs of independent professional engineer's time (Line
1 x Line 2):   This yields a total cost of $6000 for the independent
professional engineer.
      4.  Number of technical hours required for administrative duties:
Assume that eight hours are required from the owner's or operator's staff
for administrative duties connected with employing an independent
professional engineer.
      5.  Person-hour costs for technical administrative duties:  It is
assumed that the total fully-loaded costs for the owner's or operator's staff
are $30 per hour.
      6.  Total administrative costs for technical labor (Line 4 x Line
5):  Given the above assumptions, the total administrative costs for
technical labor are $240.
      7.  Number of clerical hours required for administrative duties:
Assume that five hours of clerical time are required for the necessary
typing and certification.
      8.  Person-hour costs for clerical administrative duties:  Fully-
loaded costs of clerical time are assumed to be $8.
      9.  Total administrative costs for clerical labor (Line 7 x Line 8):
Given the above assumptions, total clerical costs are $40.
      10.  Total administrative costs (Line 6 + Line 9):  Summing
technical and clerical labor, the total administrative costs are $280.
      11.  Total certification costs (Line 3 + Line 10):  The total costs
for certification, including the engineer's fees and administrative costs,
is then $6280.
                                   9-9

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G.   Total Costs Including Adm-tnistration and Contingencies
     Items 1 through 6 give the costs of all activities on each of the
preceding worksheets.  Line 7 is the total of Lines 1 through 6,
$97,210.
     8.  Administration:  For administrative tasks, including taxes,
insurance, and administration and supervision not included elsewhere,
a total of 13 percent of total costs from Line 6 is used.
     9.  Contingencies:  A general provision for contingencies of 15
percent of Line 6 has been included.
     10.  Total costs of closure (Line 7 + Line 8 + Line 9):  The
estimated total costs for closing the surface impoundment for the situation
in which all wastes remain in the impoundment are estimated for the sample
case to be $126,373.
                                   9-10

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                          SURFACE IMPOUNDMENTS
                   (All wastes remain in impoundment)
                   WORKSHEET A - REMOVING FREE LIQUID
                    AND DECONTAMINATING THE FACILITY
 1.   Method used
 2.   Time required to evaporate liquid
 3.   Cost of routine operations per day
 4.   Cost of maintenance during evaporation
      (Line 2 x Line 3)
 5.   Volume of remaining sludge
 6.   Source of sorbent materials
 7.   Cost of sorbent materials
      ($3.25/cu. yd.; 1.1 ratio)
 8.   Unit cost of mixing
 9.   Cost of mixing and stabilization
10.   Total cost of removing free liquids and sludge
      stabilization CLine 4 + Line 7 + Line 9)
11.   Decontaminating equipment
12.   Decontaminating and flushing pumps and liquid
      liners
13.   Disposing or treating residues from
      decontamination
14.   Total costs of all activities
      (Line 10 + Line 11 + Line 12 + Line 13)
Evaporation
70 days
$10
$700

1936 cu. yds.
Off-site
$6292

$1.60/cu. yd.
$6195
$13,187

$500
$2000

$1000

$16.687
                                   9-11

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                           SURFACE IMPOUNDMENTS
                    (All wastes remain in impoundment)
                         WORKSHEET B - FINAL CAP
 1.   Area to be capped                                        19,360 sq, yds.
 2.   Required impermeable material (including                 25,813 cu. yds.
      provision for suitable slope)
 3.   Source of material                                       On-site
 4.   Cost of material                                         0
 5.   Required topsoil                                         16,133 cu. yds.
 6.   Source of topsoil                                        On-site
 7.   Cost of topsoil                                          0
 8.   Cost per cu. yd. of hauling, compacting, and             $1.60
      grading impermeable material
 9.   Cost of impermeable portion of cap                       $41,301
      (Line 2 x Line 8)
10.   Cost of placing topsoil (Line 5 x Line 8)                $25,813
11.   Total cost of cap (Line 4 + Line 7 + Line 9 + Line 10)   $67.114
                                      9-12

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                          SURFACE IMPOUNDMENTS
                   (All wastes remain in impoundment)
                 WORKSHEET C - PLANTING FINAL VEGETATION
 1.   Area to be vegetated
 2.   Type of vegetation to be used
 3.   Quantity of seed per acre
 4.   Cost of seed per pound
 5.   Total cost of seed (Line 1 x Line 3 x Line 4)
 6.   Type of fertilizer to be used
 7.   Quantity of fertilizer per acre
 8.   Cost of fertilizer per ton
 9.   Total cost of fertilizer (Line 1 x Line 7 x
      Line 8)
10.   Cost of soil preparation per acre (excluding
      materials)
11.   Total cost of preparing soil (Line 1 x Line 10)
12.   Cost per acre of seeding (excluding materials)
13.   Cost of seeding (Line 1 x Line 12)
14.   Cost per acre of mulching
15.   Total mulching costs (Line 1 x Line 14)
16.   Total costs for vegetation
      (Line 5 + Line 9 + Line 11 + Line 13 + Line 15)
5 acres
Coarse grass
150 Ibs.
$.50/lb.
$375
10/10/10
.25 tons
$200/tOT
$250

$135

$675
$200
$1000
$140
$700

$2950
                                   9-13

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                          SURFACE IMPOUNDMENTS
                   (All wastes remain in impoundment)
                  WORKSHEET D - GROUND-WATER MONITORING
 1.   Number of wells monitored
 2.   Number of samples per well
 3.   Total number of samples (Line 1 x Line 2)
 4.   Number of hours required for collecting the
      sample (per sample)
 5.   Total number of hours required for collecting
      the samples (Line 3 x Line 4)
 6.   Number of hours required for preparing and
      delivering samples
 7.   Person-hour costs for collecting samples
 8.   Total sampling and collection costs
      ((Line 5 + Line 6) x Line 7)
 9.   Number of ground-water quality analyses
10.   Number of ground-water contamination analyses
11.   Unit cost of ground-water quality analysis
12.   Unit cost of ground-water contamination
      analysis
13.   Total ground-water quality analysis costs
      (Line 9 x Line 11)
14.   Total ground-water contamination analysis  costs
      (Line 10 x Line 12)
15.   Total analyses costs (Line 13 + Line 14)
16.   Number of technical hours for administration
      (e.g., reporting data to EPA)
17.   Person-hour technical costs
18.   Total technical costs for administration
      (Line 16 x Line 17)
19.  ' Number of clerical hours
20.   Person-hour clerical costs
21.   Total clerical costs (Line 19 x Line 20)
6 wells
1 sample
6 samples
2 hrs.

12 hrs.

2 hrs.

$15
$210

6 analyses
6 analyses
$77
$108

$462

$648

$1110
8 hrs.

$30
$240

5 hrs.
$8
$40
                                    9-14

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WORKSHEET D (continued)

22.  Total administrative costs  (Line 18 + Line 21)    $280
23.  Monitoring equipment maintenance                  $150
24.  Total monitoring costs                            $1750
     (Line 8 + Line 15 + Line 22 + Line 23)
                                 9-15

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                         SURFACE IMPOUNDMENTS
                  (All wastes remain in impoundment)
                    WORKSHEET E - FENCE MAINTENANCE
1.   Length of fence to be replaced                   186 feet
2.   Unit cost of replacing fence                     $13.06/linear ft.
3.   Total cost of replacing fence                    $2429
     (Line 1 x Line 2)
                                   9-16

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                           SURFACE IMPOUNDMENTS
                    (All wastes remain in impoundment)
                 WORKSHEET F - PROFESSIONAL CERTIFICATION
 1.    Number of person-hours required for inspections
 2.    Cost per person-hour
 3.    Total costs of independent professional engineer
      certification  (Line 1 x Line 2)
 4.    Number of technical hours required for administrative
      duties
 5.    Person-hour costs for technical administrative
      duties
 6.    Total administrative costs for technical labor
      (Line 4 x Line 5)
 7.    Number of clerical hours required for administrative
      duties
 8.    Person-hour costs for clerical administrative duties
 9.    Total administrative costs for clerical labor
      (Line 7 x Line 8)
10.    Total administrative costs (Line 6 + Line 9)
11.    Total certification -""sts (Line 3 + Line 10)
80 hrs,
$75
$6000

8 hrs.

$30

$240

5 hrs.

$8
$40
                                      9-17

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                          SURFACE IMPOUNDMENTS
                   (All wastes remain in impoundment)
  WORKSHEET G - TOTAL COSTS INCLUDING ADMINISTRATION AND CONTINGENCIES
 1.    Cost of removing free liquid and decontaminating       $ 16,687
      the surface and ancillary facilities (From Worksheet A)
 2.    Cost of final cap (From Worksheet B)                   $ 67,114
 3.    Cost of planting final vegetation (From Worksheet C)   $  2,950
 4.    Cost of ground-water monitoring (From Worksheet D)     $  1,750
 5.    Cost of fence maintenance (From Worksheet E)           $  2,429
 6.    Cost of professional certification (From Worksheet F)  $  6,280
 7.    Total of Line 1 through Line 6                         $ 97,210
 8.    Administration                                         $ 14,581.50
 9.    Contingencies                                          $ 14,581.50
10.    Total costs of closure (Line 7 + Line 8 + Line 9)      $126.373
                                   9-18

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               SAMPLE CLOSURE COST ESTIMATING WORKSHEETS:
      SURFACE IMPOUNDMENTS FROM WHICH WASTES ARE REMOVED AT CLOSURE

A.   Removing All Free Liquids and Sludge
     It is assumed in the sample case that free liquids will be removed
through evaporation and that sludge will be placed in a tank truck and
disposed off-site.  A variety of other options are available. For removing
free liquids, both transporting to an off-site TSDF and treating and
discharging to surface waters are other options that could be used.  For
removing sludge, solidification could take place at the site, and the
solidified sludge either disposed in an off-site landfill or in a landfill
on-site, if there was one with interim status or a permit on-site.
     1.  Method used:  As noted.above, it is assumed in this case that
evaporation is the method used to remove free liquids.
     2.  Time required to evaporate liquid:  Based on calculations that
would be shown in the closure plan, it is assumed for the sample case that
70 days would be required to evaporate liquid.
     3.  Cost of routine operations per day:  This factor includes the
required weekly inspection of the surface impoundment and a minimum allot-
ment for necessary maintenance revealed by such inspections.  This is esti-
mated to be $10 per day.
     4.  Cost of maintenance during evaporation (Line 2 x Line 3):  The
total cost of maintenance of the surface impoundment is equal to 70 times
$10 for a total of $700.
     5.  Estimated volume of sludge:  Given the size of the surface impound-
ment and the assumption of 10 percent sludge, 1936 cu. yds. of sludge will
remain after evaporation of free liquids.
     6.  Cost per cu.  yd.  of removing sludge off-site:   It is assumed
 that off-site removal of  sludges can be obtained for $40 per cu.  yd.  This
cost takes into account the fact that the off-site TSDF facility will
have to mix and stabilize the sludges, and assumes that they will, therefore,
charge a premium for this  service.
     7.  Removal costs per cu. yd.:  It is assumed for the sample facility
that removal costs are $1.60 per cu. yd. (including equipment rental).
                                   9-19

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     8.  Hauling costs per cu. yd.:  It is assumed that the nearest land-
fill is 20 miles away.  Unit costs of trucking the sludge from the impound-
ment to the landfill is assumed to be $3/cu. yd., based on discussions
with trucking industry personnel.
     9.  Total costs (per cu. yd.) of disposal (Line 6 + Line 7 + Line 8):
Total costs of off-site disposal are $44.60 per cu. yd.
    10.  Cost of removing sludge (Line 5 x Line 9):  Given these assumptions,
the cost of removing sludge, is $86,346.
    11.  Total costs (Line 4 + Line 10):  Total costs for removing free
liquids and sludges is $87,046.

B.  Decontaminating the Facility
     1.  Surface area of contaminated soil:  It is assumed that 19,360
sq. yds. (the entire surface area of the surface impoundment) has contami-
nated soil.
     2.  Depth of removal:  It is assumed in the sample case that this soil
must be removed to a depth of 1 foot to ensure that no soil contaminated
with hazardous waste remains in the surface impoundment.
     3.  Total volume to be removed (Line 1 x Line 2):  The resulting total
volume to be removed is 6453 cu. yds.
     4.  Cost of removal per cu. yd.:  The assumed cost of removing soil is
$1.60 per cu. yd. (including costs of renting equipment).
     5.  Total cost of removal  (Line 3 x Line 4):  The resulting costs for
the sample case of removing the contaminated soil are $10,325.
     6.  Cost of hauling to off-site landfill per cu. yd.:  The assumed
hauling costs to an off-site landfill for final disposal of the contaminated
soil are $3 per cu. yd.
     7.  Total cost of hauling  (Line 3 x Line 6):  The resulting total
costs of hauling are $19,359.
     8.  Fee per cu. yd. for disposal in off-site landfill:  It is assumed
that the charge per cu. yd. for off-site disposal at the chosen landfill
has been determined to be $30 per cu. yd.
     9.  Total cost of disposal (Line 3 x Line 8):  The total costs for
disposal, excluding hauling and soil removal, are then $193,590.
                                  9-20

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   10. Decontaminating equipment:  It is assumed that equipment can be
decontaminated for $500.
   11. Decontaminating and flushing pump and liquid lines:  Assume that
this can be done at the sample facility for $2000.
   12.  Disposing or treating residues from decontamination:  It is
assumed that residues resulting from the above decontamination steps
must be disposed of at a cost of $1000. .
   13. Total costs (sum of Lines 5, 7, 9, 10, 11, and 12):  The total
costs for decontaminating the surface and ancillary facilities
are $226,744.

C.  Ground-water Monitoring
    Assume that closure of the surface impoundment will require a total
of 90 days.  In order to determine the maximum possible ground-water
monitoring costs, the most extensive monitoring needed during closure is
assumed.  Assuming that ground-water quality analyses are required annually
and ground-water contamination analyses are required semi-annually, the
most expensive case is that in which both sets of analyses are required
during the 90-day closure period.
    1. Number of wells monitored:  For the sample surface impoundment, it
is assumed that six wells would need to be monitored.
    2. Number of samples per well:  One sample is taken per well for
both analyses.
    3. Total number of samples (Line 1 x Line 2):  Given the above
assumptions, six samples are required.
    4. Number of hours required for collecting the sample:  It is assumed
that experience has shown that two hours are sufficient to gather samples
from each well.
    5. Total number of hours required for collecting the samples: (Line 3
x Line 4):  For six samples, 12 hours would be required for collecting
the samples.
    6. Number of hours required for preparing and delivering the samples:
It is assumed for the example that experience has shown that this can
be done in two hours.
                                  9-21

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     5.   Person-hour costs for technical administrative duties:   It is
 assumed that the total fully loaded costs  for  the owner's or operator's
 staff are $30 per hour.
     6.   Total administrative costs  for technical labor (Line 4  x Line 5):
 Given the above assumptions,  the total administrative costs  for technical
 labor are $240.
     7.   Number of clerical hours required for  administrative duties:  Assume
that five hours of clerical time are required for the necessary typing and
certifications.
     8.   Person-hour costs for clerical administrative duties:  Fully-loaded
costs of clerical time are assumed to be $8.
     9.   Total administrative costs  for clerical labor (Line 7 x Line 8):
Given the above assumptions, total clerical costs are $40.
    10.   Total administrative costs  (Line 6 + Line 9):  Summing technical
and clerical labor, the total administrative costs are $280.
    11.   Total certification costs (Line 3 + Line 10):  The total costs for
certification, including the engineer's fees and administrative costs, is
then $4780.

E.   Total Costs of Closure Including Administration and Contingencies
     Items 1 through 4 summarize the costs of the activities on each of
the previous worksheets.
     5.  Total of Lines 1 through 4:  The total costs for the activities
listed in Lines 1 through 4 are $320,350.
     6.  Administration:  The costs for administration, which includes
insurance, taxes, and supervision and administration not included elsewhere,
are assumed to be 15 percent of Line 5.
     7.  Contingencies:  A provision for contingencies of 15 percent of
Line 5 has been included,,
     8.  Total  costs of closure  (Line 5 + Line 6 + Line 7):  The  total
costs of closure including administration and contingencies  for the sample
surface  impoundment, in the  case where  all wastes are  removed from the
impoundment, are $416,455.
                                   9-22

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    7. Person-hour costs for collecting samples:  Assume that the fully-
loaded costs for labor required for collecting, preparing and delivering
the samples averages $15 per hour.
    8. Total sample and collection costs ((Line 5 + Line 6) x Line 7):
This results in total sampling and collection costs of $210.
    9. Number of ground-water quality analyses:  One analysis must be
made for each well sample, for a total of six.
   10. Number of ground-water contamination analyses:  One analysis must
be made for each well sample, for a total of six.
   11. Unit cost of ground-water quality analyses:  It is assumed
that the cost of an analysis for the following parameters is $77 per
sample.
                       Chloride - $6.00 per sample
                       Iron - $12.00 per sample
                       Manganese - $12.00 per sample
                       Phenols - $25.00 per sample
                       Sodium - $12.00 per sample
                       Sulfate - $10.00 per sample
   12. Unit cost of ground-water contamination analysis*.  It is assumed
the cost of an analysis for the following parameters is $108 per
sample.
                       pH - $4.00 per sample
                       Specific Conductance - $4.00 per sample
                       Total Organic Carbon - $25 per sample
                       Total Organic Halogen - $75.00 per sample
   13. Total ground-water quality analysis costs (Line 9 x Line 11):
For six samples at $77 per analysis, this yields a total cost of $462.
   14. Total ground-water contamination analysis costs (Line 10 x
Line 12):  For six samples at $108 per analysis, this yields a total
cost of $648.
   15. Total analyses costs (Line 13 + Line 14):  The total analyses
costs, therefore,  are $1110.
   16. Number of technical hours for administration:  This includes
all time necessary to administer and report the data from the analysis
and is estimated as eight hours.
                                  9-23

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   17.  Person-hour technical costs:  The fully-loaded cost required for
this work is assumed to be $30 per hour.
   18.  Total technical costs for administration (Line 16 x Line 17):
Given the above assumptions, total costs for administering the tests are
assumed to be $240.
   19.  Number of clerical hours:  Assume for this case that five hours
of clerical time are required to produce the necessary reports.
   20.  Person-hour clerical costs:  Assume the fully-loaded costs for
clerical work are $8 per hour.
   21.  Total clerical costs (Line 19 x Line 20):  Given the above
assumptions, the total clerical costs are $40.
   22.  Total administrative costs (Line 18 + Line 21):  The sum of
technical and clerical costs are then $280.
   23.  Monitoring equipment maintenance:  It is assumed that an average
of $150 is required for a 90-day period to ensure adequate maintenance
of monitoring equipment and wells.
   24.  Total monitoring costs (sum of Lines 8, 15, 22, and 23):  Total
monitoring costs, excluding administration and contingencies, are then
$1750.

D.  Professional Certification
    1.  Number of person-hours required for inspections:  It is assumed
that 60 hours are required for periodic inspections of all aspects of
closing the surface impoundment.
    2.  Cost per person-hour:  In this case, assume that a registered
independent professional engineer may be hired at a cost of $75 per
hour.
    3.  Total costs of independent professional engineer's time (Line
1 x Line 2):  This yields a total cost of $4500 for the independent
professional engineer.
    4.  Number of technical hours required for administrative duties:
Assume that eight hours are required from the owner's or operator's staff
for administrative duties connected with employing an independent
professional engineer.
                                  9-24

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                           SURFACE IMPOUNDMENTS
                    (All wastes removed from impoundment)
             WORKSHEET A - REMOVING ALL FREE LIQUIDS AND SLUDGE
 1.    Method used                                              Evaporation
 2.    Time required to evaporate liquid                        70 days
 3.    Cost of routine operations per day                       $10
 4.    Cost of maintenance during evaporation                   $700
      (Line 2 x Line 3)
 5.    Estimated volume of sludge                               1936 cu. yds,
 6.    Cost of  removing sludge off-site per cu.  yd.             $40
 7.    Removal costs per cu. yd.                                $1.60
 8.    Hauling costs per cu. yd.                                $3.00
 9.    Total costs per cu. yd.  of disposal                      $44.60
      (Line 6 + Line 7 + Line 8)
10.    Costs of removing sludge (Line 5 x Line 9)               $86,346
11.    Total costs (Line 4 + Line 10)                            $87.046
                                     9-25

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                         SURFACE IMPOUNDMENTS
                 (All wastes removed from impoundment)
   WORKSHEET B - DECONTAMINATING SURPACE AND ANCILLARY FACILITIES
 1.   Surface area of contaminated soil
 2.   Depth of removal
 3.   Total volume to be removed (Line 1 x Line 2)
 4.   Cost of removal per cu.  yd.
 5.   Total cost of removal (Line 3 x Line 4)
 6.   Cost of hauling to off-site landfill per cu. yd.
 7.   Total cost of hauling (Line 3 x Line 6)
 8.   Fee per cu. yd. for disposing in off-site landfill
 9.   Total cost of disposal (Line 3 x Line 8)
10.   Decontaminating equipment
11.   Decontaminating and flushing pump and liquid lines
12.   Disposing of residues from decontamination
13.   Total costs (sum of Lines 5, 7, 9, 10, 11, and
      12)
19,360 sq. yds.
1 ft.
6453 cu. yds.
$1.60
$10,325
$3
$19,359
$30
$193,590
$500
$2000
$1000
$226.774
                                   9-26

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                          SURFACE IMPOUNDMENTS
                  (All wastes removed from impoundment)
                  WORKSHEET C - GROUND-WATER MONITORING
 1.   Number of wells monitored                          6 wells
 2.   Number of samples per well                         1 sample
 3.   Total number of samples (Line 1 x Line 2)          6 samples
 4.   Number of hours required for collecting the        2 hrs.
      sample (per sample)
 5.   Total number of hours required to collect          12 hrs.
      the samples (Line 3 x Line 4)
 6.   Number of hours required for preparing and         2 hrs.
      delivering samples
 7.   Person-hour costs for collecting samples           $15
 8.   Total sampling and collection costs ((Line         $210
      5 -I- Line 6) x Line 7)
 9.   Number of ground-water quality analyses            6 analyses
10.   Number of ground-water contamination analyses      6 analyses
11.   Unit cost of ground-water quality analysis         $77
12.   Unit cost of ground-water contamination analysis   $108
13.   Total ground-water quality analysis costs          $462
      (Line 9 x Line 11)
14.   Total ground-water contamination analysis costs    $648
      (Line 10 x Line 12)
15.   Total analyses costs (Line 13 + Line 14)           $1110
16.   Number of technical hours for administration       8 hrs.
      (e.g., reporting data to EPA)
17.   Person-hour technical costs                        $30
18.   Total technical costs for administration           $240
      (Line 16 x Line 17)
19.   Number of clerical hours                           5 hours
20.   Person-hour clerical costs                         $8
21.   Total clerical costs (Line 19 x Line 20)           $40
22.   Total administrative costs (Line 18 + Line 21)     $280
                                   9-27

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23.   Monitoring equipment: maintenance
24.   Total monitoring costs
      (Line 8 + Line 15 + Line 22 + Line 23)
                                    9-28

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                           SURFACE IMPOUNDMENTS
                   (All wastes removed from impoundment)
                 WORKSHEET D - PROFESSIONAL CERTIFICATION
 1.   Number of person-hours required for inspections
 2.   Cost per person-hour
 3.   Total costs of independent professional engineer
      certification (Line 1 x Line 2)
 4.   Number of technical hours required for administrative
      duties
 5.   Person-hour costs for technical administrative duties
 6.   Total administrative costs for technical labor
      (Line 4 x Line 5)
 7.   Number of clerical hours required for administrative
      duties
 8.   Person-hour costs for clerical administrative duties
 9.   Total administrative costs for clerical labor
      (Line 7 x Line 8)
10.   Total administrative costs (Line 6 + Line 9)
11.   Total certification costs (Line 3 + Line 10)
60 hrs,
$75
$4500

8 hrs.

$30
$240

5 hrs.

$8
$40
                                     9-29

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                          SURFACE IMPOUNDMENTS
                  (All wastes removed from Impoundment)
             WORKSHEET E - TOTAL COSTS OF CLOSURE INCLUDING
                     ADMINISTRATION AND CONTINGENCIES
1.   Cost of removing free liquids and sludge            $ 87,046
     (From Worksheet A)
2.   Cost of decontaminating facility (From              $226,774
     Worksheet B)
3.   Cost of ground-water monitoring (From Worksheet C)  $  1,750
4.   Cost of professional certification (From            $  4,780
     Worksheet D)
5.   Total of Line 1 through Line 4                      $320,350
6.   Administration                                      $ 48,052.50
7.   Contingencies                                       $ 48,052.50
8.   Total costs of closure (Line 5 + Line 6 + Line 7)   $416,455
                                    9-30

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9.3                EXAMPLE - LAND TREATMENT FACILITIES

     The following cost estimates were developed for a land treatment
facility consisting of 50 acres of active fields for the processing of
biodegradable hazardous waste.  In addition to the disposal fields, the
land treatment facility is equipped with a surface impoundment for waste
storage and a separate surface impoundment for collecting run-off water.
     The land treatment facility is designed to receive organic industrial
sludge of high liquids content.  This waste is applied to the land treat-
ment fields at an application rate of 100 wet tons/acre (solids applica-
tion rate ~5 tons/acre).
     Waste received by the facility is stored in a lined surface impound-
ment.  The surface impoundment is 5 feet deep (3 feet of waste and 2 feet
of freeboard) and has a surface area of 1.23 acres.  This corresponds to
a waste holding capacity of 160,700 cubic feet.  A pump system is avail-
able for transferring this liquid waste to the tank trucks.
     The waste from the waste storage surface impoundment is spread on
the fields using tank trucks.  During the first 90 days of the planned
closure period, all of the waste inventory will be disposed on the fields.
This disposal will require one application to the field.  Later in the
closure period, run-off water from the separate run-off water surface
impoundment will be disposed of in the same manner.  This run-off water
will have a very low concentration of hazardous wastes.  Disking of the
fields will be conducted shortly after each spreading to mix the waste
with the soil and a second disking will be done two to three weeks after
each spreading.  Periodic disking will continue on a bimonthly basis
thereafter.
     During this prolonged closure period, the surface impoundments will
be closed as well.  Each of the two surface impoundments has its own
closure plan as shown elsewhere in this guidance document.  Therefore,
the costs of decommissioning the surface impoundments are not computed
in this example.
                                   9-31

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              SAMPLES CLOSURE COST ESTIMATING WORKSHEETS:
                       LAND TREATMENT FACILITIES
A.   Disposing of Waste Inventory
     1.   Maximum inventory to be disposed:  For this case, the waste
storage surface impoundment is filled to its maximum capacity of 5000
tons of low solids waste (or 1,198,878 gallons with a waste density
similar to water).
     2.   Amount of run-off water to be disposed:  a similar
amount of somewhat contaminated water is expected to be disposed of
from the surface water run-off impoundment.  This mildly contaminated
water is to be disposed of in the same manner as the inventory.
     3.   Total material to be disposed (Line 1 + Line 2):  All of these
impounded liquids (waste and run-off) are to be disposed of on-site by
spreading on the land treatment facility fields.
     4.   Application rate:  The waste is to be applied to the field by
means of tank trucks equipped with spray bars.  The application rate of
100 tons/acre corresponds to a solids application rate of 5 tons/acre.
This application rate has been found to be acceptable based on the
operating experience of the facility.
     5.   Acreage utilized:  All 50 acres of the land treatment facility
are in active operation and will be available for the disposal of the
waste inventory and run-off.  This is the lowest cost option for disposing
inventory available to this facility.
     6.   Number of applications in the closure period:  Two applications
are planned.  One application is the liquid waste inventory which will
be completed within the first 90 days of the closure period as required
by the interim status regulations.  Subsequently, an application of the
captured run-off water is planned.
     7.   Unit cost of spreading:  The unit cost of spreading  the
liquids on the land treatment fields is $0.48 per ton or $48 per acre
at the application rate of 100 tons per acre.
     8.   Total cost of spreading (Line 5 x Line 6 x Line 7):  The total
cost of spreading the waste inventory and the captured run-off water is
the product of the acreage treated, the number of applications and the
unit per acre cost of spreading.
                                   9-32

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     9.   Number of diskings required:  A total of ten diskings will be
required throughout the closure period.  Four of the diskings will be
carried out in the first part of the closure period (immediately after
each of the two applications and several weeks after each application).
Six additional diskings will be conducted throughout the rest of the
closure period.
    10.   Unit cost of disking:  The unit cost for disking the land treat-
ment fields is the sum of tractor and implement costs and equipment
operator labor costs.  The equipment cost for disking is $.79 per acre.
The cost is for both the tractor and the tandem disk.  It includes
insurance, taxes, repairs, fuel and lubrication but it does not include
interest and depreciation.  The labor cost (fully-loaded) is $20 per
hour.  The disking is accomplished at the rate of .167 hours per acre.
In addition, extra labor time is required for related handling and care
of the equipment.  Thus, the actual labor time per acre is 1.2 times the
implement time, yielding a labor rate of $4.01 per acre.
    11.   Total cost of disking (Line 5 x Line 9 x Line 10):  The cost of
disking the land treatment fields is the product of the acreage utilized,
the number of diskings required during closure and the unit cost of
disking.
    12.   Total costs for disposing of inventory (Line 8 + Line 11):
The  total cost for disposing of the waste inventory and run-off water is
the  sum of the total spr&ading costs  and the  total disking costs.  After
completing the land  treatment, the hazardous waste will be completely
decomposed.

B.   Decontaminating the Land Treatment Facility
     1.   Area of facility contaminated:  It should be noted that the
1200 sq. yds. of contaminated soil does not include any of the land
treatment fields where controlled decomposition is occurring.
     2.   Depth of material removed:  The contaminated soil is removed
to a depth of 1 foot (.33 yds.).  The soil at this land treatment facility
is relatively  impermeable.  This makes a depth of. 1  foot  realistic for
the excavation for the contaminated soil (since the mobility of the
hazardous waste is restricted).  The soil density is 90 Ibs./cu. ft.
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     3.   Unit cost for removal:  The contaminated soil is removed and
loaded into spreaders using rented earth-moving equipment.  This excava-
tion and loading operation is estimated to cost $1.60 per cu. yd. of
contaminated soil.
     4.   Cost of removing contaminated soil (Line 1 x Line 2 x Line 3):
The cost of excavating, removing and loading the contaminated soil is
the product of the volume of the soil handled and the unit cost of the
operation.
     5.   Quantity disposed on-site:  All of the contaminated soil is to
be disposed on the land treatment fields (on-site).  The contamination
in the disposed soil will decompose under supervised conditions.  This
contaminated soil will be spread after the waste inventory has been dis-
posed.  The contaminated soil will be spread on the fields at least
several weeks after the last of the waste inventory is spread.
     6.   Quantity disposed off-site:  No contaminated soil is  to be
disposed off-site due to the much higher cost of off-site disposal and
the availability of the land treatment fields.
     7.   Application rate:  An application rate of 10 tons of contami-
nated soil per acre is used.  This solids application rate is acceptable
because the waste concentration in the soil is quite low.
     8.   Acreage utilized:  The contaminated soil is spread on the
entire 50 acres of the land treatment facility.
     9.   Number of applications:  Only one application is required to
dispose of the entire volume of contaminated soil.
    10.   Unit cost of spreading:  The unit cost for the spreading of
the contaminated soil is the sum of tractor and implement costs and
equipment operator labor costs.  The equipment cost for spreading the
waste is $.95 per acre.  This cost is for both the tractor and  the spreader.
It includes insurance, taxes, repairs, fuel and lubrication  but it  does
not include interest and depreciation.  The labor cost (fully-loaded) is
$20 per hour.  The spreading of the waste is accomplished at the rate of
.211. hours per acre.  In addition, extra labor time is required for re-
lated handling and care of  the equipment.  Thus, the actual labor time
per acre is 1.2 times the implement time, yielding a labor rate of $5.06
per acre.

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     11.  Total cost of spreading (Line 8 x Line 9 x Line 10):  The cost
of spreading the soil is the product of the acreage and the unit cost
per acre.
     12.  Number of diskings:  The spread soil is disked to mix it with
the soil of the land treatment fields.  This one disking is conducted
shortly after the contaminated soil is spread on the fields.
     13.  Unit cost of disking:  The unit cost for disking is $4.08/acre.
This cost includes equipment costs of $.79 per acre for the tractor and
the tandem disk.  This cost includes insurance, taxes, repairs, fuel and
lubrication; but it does not include interest and depreciation.  Labor
cost is included at a cost of $20 per hour.
     14.  Total cost of disking  (Line 8 x Line 12 x Line 13):  The total
cost for this disking is the product of the acres disked and the unit
cost per acre.
     15.  Total cost of disposing of contaminated soil (Line 4 4- Line
11 + Line 14):  The total cost of disposing of the contaminated soil is
the sum of the cost of removing  the soil, spreading the soil, and disking
the spread soil.
     16.  Cost of decontaminating equipment:  At the end of the closure
period, the equipment used on-site will be decontaminated by washing
with detergents.  The run-off cleaning water will be collected for dis-
posal.  A cost of $1000 is estimated for this task.
     17.  Disposing or treating  of residues from equipment decontamina-
tion:   The wastewater from the washing and other cleaning residues will
be disposed off-site at a cost of approximately $1000.  Off-site disposal
of this residue is required because the land treatment facility is
ceasing operation.
     18.  Total cost of decontaminating the facility  Line 15 + Line 16 +
Line 17):  The  total cost of decontaminating the land treatment facility
is the sum of the costs of soil  disposal, equipment decontamination,
and decontamination residue  disposal.
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C.   Monitoring Activities (Ground-Water and Soil)
Ground-Water Monitoring
     It is assumed that closure of the land treatment facility will re-
quire a total of 15 months.  In order to determine the maximum possible
ground-water monitoring costs, the most extensive monitoring needed
during closure is assumed.,  Assuming that ground-water quality analyses
are required annually and ground-water contamination analyses are required
semi-annually, the most expensive case is that in which two ground-water
quality analyses and three ground-water contamination analyses are required
during the 15-month closure period.
     1.   Number of wells monitored:  Eight sampling wells are operated
to monitor the composition of the ground-water at the land treatment
site.  Seven of the wells are downgradient from the land treatment fields
and one well is upgradient.
     2.   Number of samples taken:  Three "cycles" of ground-water samp-
ling will be conducted during the 15-month long closure period.  Two
ground-water quality analyses and three ground-water contamination
analyses are to be carried out.  One sample may be used for both the
ground-water quality and the ground-water contamination analysis.  There-
fore, during the closure period, a total of three samples are taken
from each well.
     3.   Total number of samples (Line 1 x Line 2):  The total number
of ground-water samples taken during the closure period is the product
of the number of monitoring wells and the number of samples taken from
each well.
     4.   Number of hours for collecting the sample (per sample):  Taking
ground-water samples is a rather time-consuming practice.  The well is
pumped dry and allowed to refill.  Then a sample is taken.  The land
treatment facility experience is that approximately two hours are re-
quired for each ground-water sample  (including some time for moving about
the fields).
     5.   Total number of hours for  collecting the samples (Line 3 x
Line 4):  During the extent of the closure period, 24 samples will have
to be  collected, requiring 48 hours  of labor.
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     6.   Number of hours for preparing and delivering the sample:  The
ground-water samples must also be prepared and delivered to the labora-
tory for analysis.  This work requires about three hours for a set of
eight samples (one from each monitoring well).
     7.   Total number of hours for preparing and delivering the sample
(Line 2 x Line 6):  The total number of ground-water sample preparation
and delivery hours in the closure period is the product of the number
of sets of samples (cycles) and the unit operation requirement of three
hours labor.
     8.   Person-hour costs for collecting and handling samples:  The
person^hour fully-loaded labor rate for taking and handling the ground-
water sample is $15 per hour.  This is the same labor rate as during
the operating period of the land treatment facility.
     9.   Total ground-water sampling and collection costs ((Line 5 +
Line 7) x Line 8):  The total cost of ground-water sampling is computed
by multiplying the hours required by the labor rate of $15 per hour.
    10.   Number of ground-water quality analyses:  Sixteen ground-water
quality analyses are required during the closure period.  Two analyses
are required for each well.
    11.   Number of ground-water contamination analyses:  Twenty-four
ground-water contamination analyses are required during the closure
period.  Three analyses are required for each well.
    12.   Unit cost of ground-water quality analysis.  It is assumed
that the cost of an analysis for the following parameters is $77 per
analysis.
          Chloride                 $ 6/sample
          Iron                     $12/sample
          Manganese                $12/sample
          Phenols                  $25/sample
          Sodium                   $12/sample
          Sulfate                  $10/sample
    13.   Unit cost of ground-water contamination analysis:  It is
assumed that the cost of an analysis for the following parameters is
$108 Per analysis:
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          pH                       $ 4/sample
          Specific Conductance     $ 4/sample
          Total Organic Carbon     $25/sample
          Total Organic Halogen    $75/sample
     14i-16.  Total ground-water chemical analyses costs:  The unit costs
per analysis are multiplied by the number of analyses to yield the costs-
for each type of analysis.  These two costs are added together to compute
the total analyses costs.

Soil Monitoring
     17.  Number of soil core samples:  Soil core samples are taken
throughout the closure period.  Four samples are taken in each quarter
of the first year.  In the fifth quarter of the closure period, 50
core samples are taken (one from each acre of the land treatment facility).
This last set of 50 samples confirms that the waste has decomposed during
the closure period.  Thus, a total of 66 soil core samples are taken in
the closure period (15 months in duration).  Most of these samples are
taken below the zone of waste incorporation to monitor any waste movement
towards the water table.  A few of the samples are taken from the zone
of incorporation as well to monitor the decomposition of the waste material.
     18.  Labor hours required for each core sample:  The taking of a
soil core sample is a relatively simple process.  Most of the time allo-
cated to taking each sample is movement between the sample-taking locations.
     19.  Labor unit cost for collecting core samples:  The unit cost of
the labor for soil core sampling is $15 per hour fully-loaded.
     20.  Total cost of collecting the soil samples (Line 17 x Line 18 x
Line 19):  The total cost for taking soil core samples is the product of
the number of samples taken, the hours required for each sample, and the
labor rate.
     21.  Unit soil core sample analysis cost:  The chemical analysis of
each soil sample involves the measurement of 10 parameters (organic matter,
total dissolved solids, total nitrogen, cadmium, arsenic, lead,, mercury,
chromium, zinc, and copper),  Preparing each sample costs $10 and each
parameter, costs $5.  Thus, the net cost per soil sample is $60.
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     22. Total  soil  core  sample  chemical  analysis  cost  (Line  17  x Line  21):
The  total  chemical analysis  cost for  the  soil  core samples  is the product
of the number of  samples  taken and  the  unit  analysis  cost per sample.

Lysimeter  Sampling of  Soil Moisture
     23. Number of lysimeter samples:   Soil  moisture  samples  are taken  by
means of a lysimeter.   This  extracted water  is then analyzed  for contami-
nation in  the same way that  the  ground-water samples  are chemically  analyzed,
Four soil  moisture samples are taken  during  each quarter of the  closure
period.  Since  there are  5 quarters,  a  total of 20 samples  are taken.
     24. Labor  hours required for each  lysimeter collection of soil
moisture:   One  hour  of labor is  required  for collecting and handling each
sample.  This includes time  spent moving  about the field.
     25. Labor  unit  cost  for collecting samples:   The unit  labor cost for
collecting these  samples  is  $15  per hour  fully-loaded.
     26. Total  sampling cost for lysimeter collection of soil moisture
 (Line 23 x Line 24 x Line 25) :  The total cost for collecting soil moisture
samples  is the  product of the number  of samples taken,  the  labor required
for  each sample,  and the  labor rate.
     27. Unit cost  for moisture  sample  analysis:   The unit  cost  for  each
chemical analysis is $150.   This is based on the land treatment  facility's
experience with ground-water contamination analysis and soil  moisture
chemical analysis.
     28. Total  cost  for moisture sample chemical analysis (Line  23 x
"Line 27):   The  total cost for the soil  moisture chemical analysis is
 the  product of  the  number of samples  taken and the cost of  chemically
 analyzing  each  sample.

Administrative  Costs
     29. Number of  technical hours  for  administration:   The land treat-
ment facility also  requires  the  allocation of  some technical  supervisory
 labor  to administer  the closure  monitoring program.  Approximately two
days of  such supervisory  labor will be  required in small blocks  of time
expended throughout  the closure  period.
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     30. Person-hour technical costs:  The fully-loaded labor cost for
these technically qualified employees is $30 per hour.
     31. Total technical costs for administration (Line 29 x Line 30):
The cost of this technical administration is the product of the required
technical administration hours and the technical labor rate.
     32. Number of clerical hours:  Clerical support is required for the
monitoring administration activity.  Two days of clerical labor will be
needed in small blocks of time expended throughout the closure period.
     33. Person-hour clerical cost:  The fully-loaded labor rate for
clerical labor at the land treatment facility is $8 per hour.
     34. Total clerical costs (Line 32 x Line 33):  The total clerical
costs for administering the monitoring activity is the product of the
hours required and the clerical labor rate.
     35. Total administrative costs (Line 31 + Line 34):  The technical
and clerical administrative costs are added together to yield the total
administrative costs for the monitoring program (both soil and ground-
water) for the entire closure period.

Maintenance Costs
     36. Monitoring well maintenance:  The cost of maintaining the ground-
water monitoring wells is estimated to be $750 for the entire closure
period.  No well replacements are anticipated during the closure period.

Cost Sammaries for Monitoring
     37. Total cost of ground-water monitoring (Line 9 + Line 16 + Line
36) :  The total cost for ground-water monitoring is the sum of the costs
of  sample collection, chemical analyses, and monitoring well maintenance.
     38. Total cost of soil core sample monitoring (Line 20 + Line 22):
The total cost of soil core sample monitoring is the sum of the costs
of  collecting the samples and chemically analyzing the samples.
     39. Total cost for soil moisture (lysimeter) monitoring (Line 26 4-
Line 28):  The total cost for soil moisture monitoring by means of lysimeter
samples is the sum of the costs of collecting the samples and chemically
analyzing the samples.
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     40.  Total administrative costs (Line 35):  The total administrative
costs, both clerical and technical, for the monitoring program are repeated
here.
     41.  Total monitoring costs (Line 37 + Line 38 + Line 39 + Line 40):
The total cost for the entire closure period monitoring program is the
sum of the costs of ground-water monitoring, soil core testing, lysimeter
testing, and the administrative costs.  All of these costs are reliably
known from the operating experience of the facility.

D.   Fence Maintenance
     For a land treatment facility consisting of 50 acres of active fields,
assuming that the site is square, each side is 1475.8 feet.  The perimeter
of the site is then 5903.2 feet.
     1.   Length of fence to be replaced:  Since the land treatment facil-
ity has a prolonged closure period and possible post-closure activities,
it is necessary to maintain the security fence along the field perimeters
in good condition.  We have estimated that 10% of the fencing will be
corroded and damaged to the point of requiring replacement.
     2.   Unit cost of replacing fence:  The security fence is a. galvanized
metal 6-foot high chain link fence made of #9 wire.  The installed unit
cost of replacement sections is $13.06 per linear foot.
     3.   Total cost of replacing fence (Line 1 x Line 2):  The cost of
replacing the damaged fence sections is the product of the length of the
fence needing replacement and the unit cost of replacement, for a total
of $7705.

E.   Repair of Drainage Channels
     1.   Length of drainage channels:  The land treatment facility's
drainage channels are an important part of the containment system.  They
channel run-off water to a surface impoundment.  Our estimate is that
500 feet of these channels will have to be replaced during the closure
period.
     2.   Channel volume per unit length:  The channels have a square
cross sectional area measuring 3 feet by 3 feet.  This results in a
volume of 0.33 cu. yds. per linear foot of channel length.
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     3.   Channel excavation unit cost:  The unit cost of excavating the
channels with a backhoe is $.67 per cu. yd.  This work would be performed
by a contractor and is based on contractor estimates.
     4.   Total channel excavation cost (Line 1 x Line 2 x Line 3):   This
total cost is the product of the length of the drainage channels required,
the volume per unit length, and the unit excavation cost.
     5.   Unit cost of hand grading:  The inner surface of the channels
must be shaped and prepared for seeding.  This work is performed by  hand
at a unit cost of $.02 per sq. ft.  This work will be performed by a
contractor and is based on contractor estimates.
     6.   Channel surface area:  The inside surface of the new channel
is approximately 4500 sq. ft. in area.  All of this area must be shaped
and prepared.
     7.   Total cost of hand grading (Line 5 x Line 6):  The total cost
of this hand grading is the product of the unit cost and the surface
area of the channels.
     8.   Total replanting cost:  The total cost of seeding, fertilizing
and mulching the channel surface is estimated at $50 by a contractor.
     9.   Total channel repair cost (Line 4 + Line 7 + Line 8):  The
total cost of channel repair is the sum of the excavation cost, hand grad-
ing cost and replanting cost.

F.   Management Inspection of Land Treatment Facility Operations
     1.  Number of technical management person-hours required for each
inspection :  The prolonged closure period for the land treatment facility
and the recurring operations of spreading and disking necessitate an
inspection program conducted by facility management  throughout the closure
period.  Each one of these inspections requires 8 hours of technical manage-
ment time.
     2.  Inspection frequency:  The inspections are  conducted once per
month  throughout the closure period.  On each inspection, the manager
checks  the progress of  the facility operations: spreading, disking,
sampling, decontamination, etc.
     3.  Duration of closure period:  To allow the hazardous waste to
decompose, the closure  period must be 15 months in duration.

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     4.   Total technical management person-hours required for inspections
(Line 1 x Line 2 x Line 3):  The technical hours required for the actual
inspections are the product of the number of hours for each inspection
and the total number of inspections required.
     5.  Person-hour costs for technical management duties:  The person-
hour cost for this technical supervisory labor is $30 per hour (fully-
loaded labor rate).
     6.  Total technical management costs for inspections (Line 4 x Line
5):  The technical cost for the inspections conducted throughout the
closure period is the product of the total inspection technical hours
and the technical labor rate.
     7.  Additional technical management labor required:  A small amount
of additional technical time will be required for managerial tasks
associated with the inspections (such as writing reports).  Approximately
8 percent to 10 percent of the inspection time is required for this
additional work.
     8.  Total cost of additional technical management labor (Line 5 x
Line 7):  The cost of this additional technical labor is the product of
the additional hours required and the technical labor rate.
     9.  Total cost of technical management labor (Line 6 + Line 8):
The total cost of all the technical labor required is the sum of the
labor directly spent on inspections and the labor related to inspections.
    10.  Number of clerical hours required:  Clerical labor is needed to
support the periodic inspections of the land treatment facility.   Only
a modest amount of clerical labor is required.
    11.  Person-hour costs for clerical labor:  The labor rate for
clerical labor at this facility is $8 per hour.  (This is a fully-loaded
labor rate.)
    12.  Total cost for clerical labor  (Line 10 x Line 11):  The total
cost for the needed clerical labor is the product of the clerical hours
and the clerical labor rate.
    13.  Total inspection cost (Line 9 + Line 12):  The total cost of the
inspection program is the sum of the technical labor costs and the cleri-
cal labor costs.
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G.   Professional Certification
     1.  Number of person-hours required for inspections:  Approximately
one week of professional time will be required to certify the proper
closure of the land treatment facility.  Most of this professional work
will be an independent professional engineer as specified by the interim
status regulations.  The professional engineer will be assisted by a soil
specialist who will evaluate the soil samples taken during the closure
period.
     2.  Cost per person-hour:  The contracted cost of these professionals
is $75 per hour based on their current quotes for these services.
     3.  Total costs of professional engineer's time (Line 1 x Line 2):
The total cost for these contracted professional services is the product
of the number of hours required and the quoted hourly rate.
     4.  Number of technical hours required for administrative duties:
The land treatment facility technical staff will need to devote 8 hours
of time to administering this certification.
     5.  Person-hour costs for technical administrative duties:  The
fully-loaded labor rate for the technical staff is $30/hour.
     6.  Total administrative costs for technical labor (Line 4 x Line 5):
The technical administrative costs for the land treatment facility is  the
product of the number of technical hours required and the technical labor
rate.
     7.  Number of clerical hours required for administrative duties:
Eight hours of clerical work are required to support the administration
of the certification.
     8.  Person-hour costs for clerical administrative duties:  The
fully-loaded labor rate for clerical workers at this facility is $8/hour.
     9.  Total administrative costs for clerical labor (Line 7 x Line  8):
The total clerical labor costs are the product of the labor rate and
the number of hours required.
    10.  Total administrative costs (Line 6 + Line 9):  The total adminis-
trative costs are the sum of the technical labor cost and the clerical
labor cost.
    11.  Total certification costs (Line 3 + Line 10):  The total cost
for certification is the sum of the costs of the professional engineer
                                   9-44

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and the administrative costs.

 H.  Total Costs Plus Administration and Contingencies
     Items 1 through 7 give the costs of each major closure function on
each of the preceding worksheets.  Line 8 is the total of Lines 1 through
7, $39,389.
     7.  Administration:  All additional administration costs are com-
puted by multiplying the subtotal (Line 8) by 15 percent.
     8.  Contingencies:  Allowance for contingencies is computed by
multiplying the subtotal (Line 8) by 15 percent.
     9.  Total costs of closure (Line 8 + Line 9 + Line 10):  A grand
total for land treatment facility closure costs is computed by adding
together the costs from the worksheets and the allowances for additional
administration and other contingencies.
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                        LAND TREATMENT FACILITIES
                WORKSHEET A - DISPOSING OF WASTE INVENTORY

 Method of Disposal:  Spreading on the Land Treatment Fields
 1.   Maximum inventory to be disposed

 2.   Run-off water to be disposed
 3.   Total material to be disposed (Line 1 + Line 2)
 4.   Application rate (wet weight)
 5.   Acreage utilized
 6.   Number of applications in the closure period
 7.   Unit cost of spreading
 8.   Total cost of spreading (Line 5 x Line 6 x Line 7)
 9.   Number of diskings required during the
      closure period (excluding one disking for
      decontamination)
10.   Unit cost of disking (equipment cost and labor)
11.   Total cost of disking (Line 5 x Line 9 x Line 10)
12.   Total cost for disposing of inventory and
      run-off water (Line 8 + Line 11)
5000 tons of
liquid waste.
5000 tons
10,000 tons
100 tons/acre
50 acres
2
$48/acre
$4800
10
$4.80/aare
$2400
$7200
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                       LAND TREATMENT FACILITIES
               WORKSHEET B - DECONTAMINATING THE FACILITY
 1.   Area of facility contaminated
 2.   Depth of material removed
 3.   Unit cost for removal (including machinery rental)
 4.   Cost of removing the contaminated soil
      (Line 1 x Line 2 x Line 3)
 5.   Quantity of contaminated soil disposed on-site by
      landspreading
 6.   Quantity of contaminated soil disposed off-site
 7.   Application rate
 8.   Acreage utilized
 9.   Number of applications
10.   Unit cost of spreading (equipment cost and labor)
11.   Total cost for spreading the contaminated soil
      on the land treatment fields (Line 8 x Line 9
      x Line 10)
12.   Number of diskings carried out to assist
      in disposing of contaminated soil
13.   Unit cost of disking (equipment cost and labor)
14.   Total cost for disking the spread soil into the
      land treatment soil (Line 8 x Line 12 x Line 13)
15.   Total cost of disposing of the contaminated soil
      (Line 4 + Line 11 + Line 14)
16.   Cost of decontaminating equipment
17.   Disposing of residues from equipment decon-
      tamination
18.   Total cost of decontaminating the facility
      (Line 15 + Line 16 + Line 17)
 1200 sq. yds.
.33 yds. (1 ft.)
$1.60/cu. yd.
$633.60

396 cu. yds.
(481 tons)
0
10 tons/acre
50 acres
1
$6/acre
$300
$4.80/acre
$240

$1173.60

$1000
$1000

$3173.60
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                        LAND TREATMENT FACILITIES
                   WORKSHEET C - MONITORING ACTIVITIES
                   (GROUND-WATER AND SOIL MONITORING)
 Ground-Water Monitoring
 1.   Number of wells monitored
 2.   Number of samples taken at each well (1 per cycle)
 3.   Total number of samples (Line 1 x Line 2)
 4.   Number of hours for collecting the sample (per sample)
 5.   Total number of hours for collecting the samples
      (Line 3 x Line 4)
 6.   Number of hours for preparing and delivering sample
      (per each sampling cycle of eight wells)
 7.   Total number of hours for preparing and delivering
      sample (Line 2 x Line 6)
 8.   Person-hour costs for collecting and handling samples
 9.   Total ground-water sampling and collection costs
      ((Line 5 + Line 7) x Line 8)
10.   Number of ground-water quality analyses
11.   Number of ground-water contamination analyses
12.   Unit cost of ground-water quality analysis
13.   Unit cost of ground-water contamination analysis
14.   Total ground-water quality analysis costs
      (Line 10 x Line 12)
15.   Total ground-water contamination analysis costs
      (Line 11 x Line 13)
16.   Total ground-water chemical analyses costs
      (Line 14 + Line 15)
 Soil Monitoring
      Soil Core Sampling;
17.   Number of soil core samples taken during the
      closure period
18.   Labor hours required for each core sample
      (includes movement between sampling locations)
19.   Labor unit cost for collecting core sample
8 wells
3 samples
24 samples
2 hours
48 hours

3 hours

9 hours

$15/hour
$855

16 analyses
24 analyses
$77
$108
$1232

$2592

$3824
66 samples
.5 hours
$15/hour
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WORKSHEET C (continued)

20.  Total cost of collecting soil samples for the entire     $495
     closure period (Line 17 x Line 18 x Line 19)
21.  Unit soil core sample analysis cost (10 parameters)      $60
22.  Total soil core sample chemical analysis cost            $3960
     (Line 17 x Line 21)
     Lysimeter Sampling of Soil Moisture;
23.  Number of lysimeter samples taken during the             20
     closure period
24.  Labor hours required for each lysimeter collection       1 hour
     of soil moisture
25.  Labor unit cost for collecting samples                   $15/hour
26.  Total sampling cost for lysimeter collection             $300
     of soil moisture  (Line 23 x Line 24 x Line 25)
27.  Unit cost for moisture sample analysis                   $150
28.  Total cost for moisture sample chemical analysis         $3000
     (Line 23 x Line 27)
Administrative Costs
29.  Number of technical hours for administration             16 hours
30.  Person-hour technical costs                              $30/hour
31.  Total technical costs for administration                 $480
     (Line 29 x Line 30)
32.  Number of clerical hours                                 16 hours
33.  Person-hour clerical cost                                $8
34.  Total clerical costs (Line 32 x Line 33)                 $128
35.  Total administrative costs (Line 31 + Line 34)           $608
Maintenance Costs
36.  Monitoring well maintenance (includes maintenance        $750
     of associated equipment)
Cost Summaries for Monitoring
37.  Total cost of ground-water monitoring for the            $5429
     closure period (Line 9 + Line 16 + Line 36)
38.  Total cost of soil core sample monitoring for            $4455
     the closure period (Line 20 + Line 22)
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WORKSHEET C (continued)

39.  Total cost for soil moisture (lysimeter) monitoring      $3300
     for the closure period (Line 26 + Line 28)
40.  Total administrative costs (Line 35)                     $608
41.  Total monitoring costs for the entire closure            $13,792
     period (Line 37 + Line 38 + Line 39 + Line 40)
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                       LAND TREATMENT FACILITIES
                    WORKSHEET D - FENCE MAINTENANCE

1.   Length of fence to be replaced                        590 feet
2.   Unit cost of replacing fence                          $13.06/linear ft,
3.   Total cost of replacing fence (Line 1 x Line 2)        $7705
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                        LAND TREATMENT FACILITY
                WORKSHEET E - REPAIR OF DRAINAGE CHANNELS
1.   Length of drainage channels requiring excavation
2.   Channel volume per unit length

3.   Channel excavation unit cost
4.   Total channel excavation cost
     (Line 1 x Line 2 x Line 3)
5.   Unit cost for hand grading
6.   Channel surface area to be prepared by hand
7.   Total cost of hand grading (Line 5 x Line 6)
8.   Total replanting cost (including seed,
     fertilizer and mulch)
9.   Total channel repair cost
     (Line 4 + Line 7 + Line 8)
500 feet
.33 cu. yds.
per linear ft.
$.67/cu. yd.
$11.05

$.02/sq. ft.
4500 sq. ft.
$90
$50

$250.55
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                         LAND TREATMENT FACILITIES
                 WORKSHEET F - MANAGEMENT INSPECTION OF LAND
                        TREATMENT FACILITY OPERATIONS
 1.   Number of technical management person-hours
      required for each inspection of the land treatment
      facility
 2.   Inspection frequency
 3.   Duration of closure period
 4.   Total technical management person-hours required
      for inspections during the closure period
      (Line 1 x Line 2 x Line 3)
 5.   Person-hour costs for technical management duties
 6.   Total technical management costs for land treatment
      facility inspections (Line 4 x Line 5)
 7.   Additional technical management labor required
      related to the inspection program
 8.   Total cost of the additional technical management
      labor (Line 5 x Line 7)
 9.   Total cost of technical management labor
      (Line 6 + Line 8)
10.   Number of clerical hours required
11.   Person-hour costs for clerical labor
12.   Total cost for clerical labor' (Line 10 x Line 11)
13.   Total inspection cost (Line 9 + Line 12)
8 hours
1 per month
15 months
120 hours
$30
$3600

10 hours

$300

$3900
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                        LAND TREATMENT FACILITIES
                  WORKSHEET G - PROFESSIONAL CERTIFICATION
 1.   Number of person-hours required for inspecting           40 hours
      the land treatment facility and its operating records
 2.   Cost per person-hour                                     $75
 3.   Total costs of professional engineer's time              $3000
      (Line 1 x Line 2)
 4.   Number of technical hours required for administrative    8 hours
      duties
 5.   Person-hour costs for technical administrative duties    $30
 6.   Total administrative costs for technical labor           $240
      (Line 4 x Line 5)
 7.   Number of clerical hours required for administrative     8 hours
      duties
 8.   Person-hour costs for clerical administrative duties     $8/hour
 9.   Total administrative costs for clerical labor            $64
      (Line 7 x Line 8)
10.   Total administrative costs (Line 6 + Line 9)
11.   Total certification cost (Line 3 + Line 10)
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                         LAND TREATMENT FACILITIES
               WORKSHEET H - TOTAL COSTS PLUS ADMINISTRATION
                              AND CONTINGENCIES
 1.   Cost of disposing of inventory (From Worksheet A)       $ 7,200
 2.   Cost of decontaminating the facility (From Worksheet B) $ 3,173
 3.   Cost of monitoring (From Worksheet C)                   $13,792
 4.   Cost of fence maintenance (From Worksheet D)            $ 7,705
 5.   Cost of repairing drainage channels (From Worksheet E)  $   251
 6.   Cost of management inspections (From Worksheet F)       $ 3,964
 7.   Cost of professional certification of closure           $ 3,304
      (From Worksheet G)
 8.   Total of Line 1 through Line 7                          $39,389
 9.   Administration                                          $ 5,908
10.   Contingencies                                           $ 5,908
11.   Total costs of closure (Line 8 + Line 9 + Line 10)      $51,205
                                   9-55

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9.4                        EXAMPLE - LANDFILLS

     For illustrative purposes, a sample cost estimate has been developed
for a landfill with the following characteristics:  the landfill has been
in operation for 10 years and covers approximately 75 acres.  Sixty-five
acres have been partially closed (i.e., they have been filled with waste,
an adequate cap and vegetative cover established and maintained).  Ten
acres of the landfill are currently in active use and have not received
final cap or cover but are largely filled.  Of the 65 acres which have
received final cap and cover, it is assumed that approximately 5 acres
are in need of revegetation due to failure of original vegetation over
the life of the facility.  The landfill accepts hazardous solid waste re-
ceived in trucks.   Waste is received for this site in 55-gallon drums.
                                   9-56

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          SAMPLE CLOSURE COST ESTIMATING WORKSHEETS:  LANDFILLS

A.   Disposing of Inventory
     1.  Volume of waste when processed for landfill disposal:  It is
estimated from the closure plan that the most expensive closure conditions
likely to occur over the life of facility would result in 900 55-gallon drums
of waste to be disposed and no trench yet constructed for their disposal.
This situation would occur when existing trenches had been filled but not
yet capped, and waste continued to be accepted for further disposal.
This estimate should be based on the volume of the waste after conducting
the necessary processing prior to disposal.  For example, if sludge is
taken in, the proper volume to be used is that of solidified sludge, not
the volume of the sludge as it enters the facility.  In this case, since
waste is accepted in drums only, there is no need for further calculation.
     2.  Estimated volume of contaminated soil residues disposed
of through on-site landfill operations:  This volume is determined from
Worksheet B.
     3.  Total volume of wastes to landfills on-site (Line 1 + Line 2):
In this case, the total volume to be landfilled on-site is the volume of
inventory (800 cu. yds.) plus the estimate volume of residues and con-
taminated material to be disposed of on-site from Worksheet B (600 cu.
~ds.).  It is possible in some cases that not all inventory could be
disposed of on-site.  For example, if two wastes normally are neutralized
by combination, and there is inadequate volume of one of the wastes to
complete neutralizing the second waste at the time closure commences,
some portion of the second waste would have to be disposed of off-site.
     4.  Estimated cost of constructing a trench:   The cost of construct-
ing a trench adequate for 1400 cu. yds. of material of the type indicated,
including adequate liner, is estimated as $18,000, based upon past trench
construction experience at the facility.
     5.  Estimated cost of placing wastes in trench (excluding final
cover and vegetation) :  Based on the annual volume and operating costs
of the facility (excluding profits and depreciation), it is estimated
that the costs of placing this waste will be $6000,
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     6.  Total cost of disposing of inventory (Line 4 + Line 5):  The
total cost of disposing of inventory are then the sum of Lines 4 and 5.

B.   Decontaminating the Facility
     1.  Area of facility contaminated:   It is assumed  in  the  example  that
at the end of facility life, approximately 1800 sq. yds. of the surface of
the facility will show sufficient contamination to justify its disposal
as hazardous waste.
     2.  Depth of material removed:  It is assumed that removal to 1 foot
will be necessary.
     3.  Cost of removal:  The assumed cost of removing this material
is $1.40 per cu. yd. for a total cost of $840.  This does not include
the costs of disposing of the material.
     4.  Quantity disposed on-site:  For the sample problem, it is
assumed that all 600 cu. yds. will be disposed on-site.
     5.  Quantity disposed at an off-site TSDF:  None of the material
removed will be disposed off-site.
     6.  Cost to decontaminate equipment;  It is  assumed that $1000 will be
sufficient for decontaminating equipment.
     7.  Volume of waste resulting from decontaminating equipment:  It
is estimated that 25 cu. yds. of material will need to be disposed of
as a result of decontaminating equipment.
     8.  Unit cost of off-site disposal:  Contact with other area
hazardous waste disposal facilities indicates that land disposal for
these wastes would currently cost $40/cu. yd.
     9.  Unit cost of hauling:  Hauling this small quantity of residue
20 miles to nearest landfill will cost $10 per cu, yd. according to
local trucking concerns.
    10.  Total cost of off-site disposal (Line 7 x Line 8):  Total costs
of disposing residue are then $1000.
    11.  Total cost of hauling (Line 7 x Line 9):  Total cost of hauling
is then the unit cost of hauling times the total volume of residues to
be disposed.
    12.  Total cost of decontaminating the facility (.Line 3 + Line 6 + Line
10 + Line 11):  Total costs are then $2850.

                                    9-58

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C.   Placing Final Cap
     As noted in the summary of this example, it has been assumed that
the equipment for all necessary earth work is available on-site.  As a
result, costs for placing a final cap over the fill area include only
labor, operating costs, and materials, not costs associated with rent-
ing equipment or capital recovery factors for purchased equipment.
     1.  Area to be capped:  The example assumed that 10 acres, or 48,400
sq. yds., will remain open and require both a clay cap and topsoil.
     2.  Type of material used for impermeable layer:  Clay is the
impermeable material specified in the closure plan.
     3.  Depth of impermeable layer:  It is assumed that 2 ft. of clay
will provide an adequate cap.
     4.  Volume of material required (Line 1 x Line 3):  The amount of
clay required is 32,428 yds. (48,400 x .67 yds.).
     5.  Source of impermeable material:  It is assumed that clay is
available on-site as a result of previous excavations, at a haul distance
of 800 yds. or less.
     6.  Cost of impermeable material:  Because the material is available
on-site, the cost is zero.
     7.  Depth of topsoil required:  It is assumed that 2 ft. of topsoil
will be adequate to ensure that the roots from vegetation of the fill
area do not penetrate the clay cap.
     8.  Volume of topsoil required (Line 1 x Line 7):  The amount of
topsoil required is 32,428 cu. yds.
     9.  Source of topsoil:  Again, it is assumed that adequate topsoil
is available on-site from previous excavations.
    10.  Cost of topsoil:  The cost in this case is zero, since the
material is available on-site. (If topsoil were not available on-site,
a cost estimate would have to be developed through discussions with local
suppliers, etc.)
    11.  Cost per cu. yd. for hauling, spreading and compacting clay and
topsoil:  In the example, it is assumed that this can be done for $1.20
per cu. yd.
    12.  Cost of placing impermeable portion of cap (Line 4 x Line 11) :
Based on these'assumptions, the costs of placing the impermeable portion
                                   9-59

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of the cap would be $38,914.
     13. Cost of placing topsoil (Line 8 x Line 11):  Based on the assump-
tions, the costs of placing topsoil are also $38,914.
     14. Total costs of final cap (sum of Lines 6, 10, 12, and 13):  The
total costs of the final capping operation will be $77,828.  This does
not include administrative expenses or contingency planning, both of
which are calculated on Worksheet G.

D.   Planting Final Vegetation
     As in the above worksheets, it is assumed that all necessary equip-
ment is available on-site, but that material and labor costs will be
accrued during the closure exercise.
     1.  Area not yet vegetated:  The area remaining open at the time
of closing is 10 acres.
     2.  Area already closed but requiring replanting:  It is assumed
in this case that 5 acres of the closed portion of the landfill require
replanting, due to the failure of original vegetation efforts.
     3.  Total area to be planted (Line 1 + Line 2):  The sample
case provides for 15 acres to be planted during closure.
     4.  Type of vegetation to be used:  In this example, it is assumed
that coarse field grass (a mixture of rye grass and Kentucky fescue)
will be employed for final vegetation.
     5.  Quantity of seed used per acre:  According to industry suppliers,
150 Ibs. of seed should be applied per acre.
     6.  Cost of seed per pound:  Calls to local suppliers determined that
seed is available at $.50/lb.
     7.  Total cost of seed (Line 3 x Line 5 x Line 6):  Given the above
assumptions, the total cost of seed will be $1125.
     8.  Type of fertilizer to be used:  Given the topsoil and climatic
conditions, 10/10/10 fertilizer is assumed to be adequate.
     9.  Quantity of fertilizer per acre:  .25 tons is assumed to be
reasonable, given the quality of topsoil and the climatic conditions.
    10.  Cost of fertilizer per ton:  According to local suppliers,
fertilizer is available for $200/ton.
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     11.  Total cost of fertilizer (Line 3 x Line 9 x Line 10):  Given
the above assumptions, the total cost of fertilizer is $750.
     12.  Cost of soil preparation per acre:  Preparing the soil includes
both disking and fertilizing and is assumed to be $100 per acre.
     13.  Total cost of preparing soil (Line 3 x Line 12):  The total
cost of preparing soil, excluding materials such as fertilizers, is,
given the above assumptions, $1500.
     14.  Cost per acre of seeding (excluding cost of seed):  It is
assumed for the sample facility that seeding will cost $150 per acre.
     15.  Total cost of seeding (excluding seed) (Line 3 x Line 14):
Given the above assumptions, the total cost of seeding for the facility is
$2250.
     16.  Cost per acre of mulching:  The cost per acre of purchasing and
applying a hay mulch is assumed to be $120.
     17.  Total mulching costs (Line 3 x Line 16):  Given the above assump-
tions, total mulching costs, including costs of hay, are $1800 for the

     18.  Total costs for vegetation (sum of Lines 7, 11, 13, 15, and 17):
The total costs for establishing vegetation are $7425.

E.   G_round-Water Monitoring
     Assume that closure of the landfill will require a total of 90 days.
In order to determine the maximum possible ground-water monitoring costs,
the most extensive monitoring needed at closure is assumed.  Assuming
that ground-water quality analyses are required annually and ground-water
contamination analyses are required semi-annually, the most expensive
case is that in which both sets of analyses are required during the 90-
day closure period,
     1.   Number of wells monitored:  For the sample landfill, it is assumed
that eight wells would need to be monitored.
     2.   Number of samples per well:  One sample is taken per well for
both analyses.
     3.   Total number of samples (Line 1 x Line 2):  Given the above
assumptions, eight samples are required.
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     4.   Number of hours required for collecting the sample:  It is
assumed that experience has shown that 2 hours are sufficient to
gather samples from each well.
     5.   Total number of hours required for collecting the samples
(Line 3 x Line 4):  For eight samples, 16 hours are required for collec-
ting the samples.
     6.   Number of hours required for preparing and delivering the
sample:  It is assumed for the example that experience has shown that
this can be done in 3 hours.
     7.   Person-hour costs for collecting samples:  Assume that the
fully-loaded costs, for labor required for collecting, preparing and
delivering the sample averages $15 per hour.
     8.   Total sampling and collecting costs  ((Line 5 + Line 6) x Line  7)
This results in total sampling and collection costs of $285.
     9.   Number of ground-water quality analyses:  One analysis must
be made for each well sample, for a total of eight.
    10.   Number of ground-water contamination analyses:  One analysis
must be made for each well sample, for a total of eight.
    11.   Unit cost of ground-water quality analysis.  It is assumed
that the cost of an analysis for the following parameters is $77 per
sample:
          Chloride                 $ 6/sample
          Iron                     $12/sample
          Manganese                $12/sample
          Phenols                  $25/sample
          Sodium                   $12/sample
          Sulfate                  $10/sample
    12.   Cost of ground-water contamination analysis.  It is assumed
that an analysis for the following parameters is $108 per sample:
          pH                       $ 4/sample
          Specific Conductance     $ 4/sample
          Total Organic Carbon     $25/sample
          Total Organic Halogen    $75/sample
    13.   Total ground-water quality analysis costs (Line 9 x Line 11):
For eight samples at $77 per analysis, this yields a total cost of $616.
                                   9-62

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     14.  Total ground-water contamination analysis costs  (Line 10 x
Line 12):  For eight samples at $108 per analysis, this yields a total
cost of $864.
     15.  Total analysis costs (Line 13 + Line 14):  The total analyses
costs, therefore, are $1480.
     16.  Number of technical hours for administration:  This includes
all time necessary to administer and report the data from  the analyses
and is estimated as 8 hours.
     17.  Person-hour technical costs:  The fully-loaded cost required
for this work is assumed to be $30 per hour.
     18.  Total technical costs for administration (Line 16 x Line 17):
Given the above assumptions, total costs for administering the tests
are assumed to be $240.
     19.  Number of clerical hours:  Assume for this case  that 5 hours of
clerical time are required to produce the necessary reports.
     20.  Per-hour clerical costs:  Assume the fully-loaded costs for
clerical work are $8 per hour.
     21.  Total administrative costs (Line 19 x Line 20):  Given the above
assumptions, the total clerical costs are $40.
     22.  Total administrative costs (Line 18 + Line 21):  The sum of
technical and clerical costs are then $280.
     23.  Monitoring equipment maintenance:  It is assumed that an average
of $150 is required for a 90-day period to ensure adequate maintenance of
monitoring equipment and wells.
     24.  Total monitoring costs^ (sum of Lines 8, 15, 22,  and 23):  Total
monitoring costs, excluding administration and contingencies, are then
$2195.

F.   Fence Maintenance
     For a 75-acre site, assuming that the site is square, each side of
the site is 1807 feet in length.  The perimeter of the site is then
7228 feet.
     1.   Length of fence to be replaced:  It is expected  that some
sections of the facility's security fence will have corroded and will
have to be replaced.  Our estimate is that 10% of the perimeter fence
will have to be replaced.
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     2.   Unit cost of replacing fence:  The security fence around the
facility perimeter is a galvanized metal chain link fence 6 feet high.
This fence is made of #9 wire.  The unit replacement cost for this
fence is $13.06 per linear foot.
     3.   Total cost of replacing fence (Line 1 x Line 2):  The cost of
fence replacement is the product of the length of fence needing re-
placement and the unit cost of replacement, for a total of $9442.

G.   Professional Certification

     1.   Number of person-hours required for inspections:  It is
assumed that 80 hours are required for periodically inspecting all as-
pects of closure of the landfill.
     2.   Cost per person-hour:  In this case, assume that a registered
independent professional engineer may be hired at a cost of $75 per hour.
     3.   Total costs of independent professional engineer's time (Line
1 x Line 2) :  This yields a. total cost of $6000 for the independent
professional engineer.
     4.   Number of technical hours required for administrative duties:
Assume that 8 hours are required from the owner/operator's staff for
administrative duties connected with employing an independent professional
engineer.
     5.   Person-hour costs for technical administrative duties:  It is
assumed that the total fully-loaded costs for the owner/operator's rtaff
are $30 per hour.
                                          %
     6.   Total administrative costs for technical labor  (Line 4 x Line 5):
Given the above assumptions,  the total administrative costs for technical
labor are $240.
     7.  Number of  clerical hours required  for administrative duties:
Assume  that 5 hours of clerical  time are required  for  the necessary  typing
and certifications.
     8.  Person-hour  costs  for  clerical administrative  duties:.   Fully-
loaded  costs of clerical time are assumed to be $8.
     9.  Total administrative costs for clerical labor  (Line 7 x Line  8):
Given  the above assumptions,  total clerical costs  are  $40.

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    10.  Total administrative costs (Line 6 4- Line 9):  Summing  technical
and clerical labor, the total administrative costs are $280.
    11.  Total certification costs (Line 3 + Line 10):  The total costs
for certification, including the engineer's fees and administrative costs,
is then $6280.

H.   Total Closure Costs Including Administration and Contingencies
     Lines 1 through 7 of this Worksheet simply summarize the total closure
costs, excluding administration and contingencies, from each of  the prior
worksheets.

      8.   Total of Lines  1 through 7:   The total costs  for the activities
 listed in Lines 1 through 7 are $130.020.
      9.   Administration:   For  administrative  tasks,  including taxes,
 insurance,  and administration  and supervision not  included  elsewhere,
 a total of 15 percent  of  total costs  from Line 8 is  used.
     10..  Contingencies:   A general provision  for contingencies  of 15
 percent of total costs has been included.
     11.   Total closure costs (Line 8  + Line 9 + Line 10):   The  estimated
 total closure costs  are  then $169,026.
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                                LANDFILLS
                    WORKSHEET A - DISPOSING OF INVENTORY
1.   Volume of waste when processed for disposal         800 cu. yds.
2.   Estimated volume of residue and contaminated        600 cu. yds.
     soil to be disposed through on-site landfill
     operation
3.   Total volume of waste to be landfilled on-site      1400 cu. yds.
     (Line 1 + Line 2)
4.   Estimated cost of constructing trench               $18,000
5.   Estimated cost of placing waste in                  $ 6,000
     trench
6.   Total cost of disposing of inventory                $24,000
     (Line 4 + Line 5)
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                                 LANDFILLS
                WORKSHEET B - DECONTAMINATING THE FACILITY
 1.   Area of facility contaminated                       1800 sq. yds.
 2.   Depth of material removed                           .33 yd. (1 ft.)
 3.   Cost of removal                                     $840
 4.   Quantity disposed on-site (see Worksheet A          600 cu. yds.
      to develop cost)
 5.   Quantity disposed off-site                          0
 6.   Cost to decontaminate equipment                     $1000
 7.   Volume of waste resulting from decontaminating      25 cu. yds.
      equipment
 8.   Unit cost of off-site disposal ($/cu. yd.)
 9.   Unit cost of hauling ($/cu.  yd.)
10.   Total cost of disposing off-site  (Line 7 x Line 8)
11.   Total cost of hauling (Line 7 x Line 9)
12.   Total costs of decontaminating the facility
      (Line 3 + Line 6 + Line 10 + Line 11)
                                    9-67

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                                 LANDFILLS
                    WORKSHEET C - PLACING FINAL CAP
 1.   Area to be capped (include sum of all portions
      of the facility remains open and any portions of
      the facility opened to dispose of inventory and
      wastes from the process of decontamination)
 2.   Type of material used for impermeable layer
48,400 sq. yds.
(10 acres)
Clay with perm-
eability of 10™7
 3.   Depth of material of impermeable layer
 4.   Volume of material to be used for impermeable
      layer (Line 1 x Line 3)
 5.   Source of impermeable material
 6.   Cost of impermeable material
 7.   Depth of topsoil
 8.   Volume of topsoil (Line 1 x Line 7)
 9.   Source of topsoil
10.   Cost of topsoil
11.   Cost per cu. yd. for hauling, spreading and
      compacting
12.   Cost of impermeable portion of cap
      (Line 4 x Line 11)
13.   Cost of placing topsoil (Line 8 x Line 11)
14.   Total costs (Line 6 + Line 10 + Line 12 + Line 13)
.667 yds. (2 ft.)
32,428 cu. yds,

On-site from
previous exca-
vations
0
.667 yds. (2 ft.)
32,428 cu. yds.
On-site from
previous exca-
vations
0
$1.20

$38,914

$38,914
$77,828
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                                 LANDFILLS
                  WORKSHEET D - PLANTING FINAL VEGETATION
 1.   Area not yet vegetated (should be approximately
      equivalent to area remaining open)
 2.   Area already closed but in need of some replantin-g
      prior to final closure
 3.   Total area to be planted (Line 1 + Line 2)
 4.   Type of vegetation to be used
 5.   Quantity of seed per acre
 6.   Cost of seed per pound
 7.   Total cost of seed (Line 3 x Line 5 x Line 6)
 8.   Type of fertilizer to be used
 9.   Quantity of fertilizer per acre
10.   Cost of fertilizer per ton
11.   Total cost of fertilizer (Line 3 x Line 9 x
      Line 10)
12.   Cost of soil preparation per acre
13.   Total cost of preparing soil (excluding
      materials) (Line 3 x Line 12)
14.   Cost per acre of seeding (less materials)
15.   Cost of seeding  (Line 3  x Line 14)
16.   Cost per acre of mulching
17.   Total mulching costs  (Line 3 x'Line 16)
18.   Total costs for vegetation
      (Line 7 + Line 11 + Line 13 + Line 15 + Line 17)
10 acres

5 acres

15 acres
Coarse grass
150 Ibs.
$.50
$1125
10/10/10
.25 tons
$200
$750

$100
$1500

$150
$2250
$120
$1800
$7425
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                                LANDFILLS
                  WORKSHEET E - GROUND-WATER MONITORING
 1.   Number of wells monitored                               8 wells
 2.   Number of samples per well                              1 sample
 3.   Total number of samples (Line 1 x Line 2)               8 samples
 4.   Number of hours required for collecting sample          2 hours
      (per sample)
 5.   Total number of hours required for collecting samples   16 hours
      (Line 3 x Line 4)
 6.   Number of hours required for preparing and delivering   3 hours
      samples
 7.   Person-hour coats for collecting samples                $15
 8.   Total sampling and collection costs                     $285
      ((Line 5 + Line 6) x Line 7)
 9.   Number of ground-water quality analyses                 8 analyses
10.   Number of ground-water contamination analyses           8 analyses
11.   Unit cost of ground-water quality analysis              $77
12.   Cost of ground-water contamination analysis             $108
13.   Total ground-water quality analysis costs               $616
      (Line 9 x Line 11)
14.   Total ground-water contamination analysis costs         $864
      (Line 10 x Line 12)
15.   Total analyses costs (Line 13 4- Line 14)                $1480
16.   Number of technical hours for administration (e.g.,     0 ,
                                                              8 hours
      reporting data to EPA)
17.   Person-hour technical costs                             $30
18.   Total technical costs for administration                $240
      (Line 16 x Line 17)
19.   Number of clerical hours                                5 hours
20.   Person-hour clerical costs                              $8
21.   Total clerical costs  (Line 19 x Line 20)                $40
22.   Total administrative costs  (Line 18 -f- Line 21)          $280
                                    9-70

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WORKSHEET E - continued

23.  Monitoring equipment maintenance
24.  Total monitoring costs (Line 8 + Line 15 +
     Line 22 + Line 23)
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                               LANDFILLS
                    WORKSHEET F - FENCE MAINTENANCE
1.   Length of fence to be replaced                          723 feet
2.   Unit cost of replacing fence                            $13.067
                                                             linear ft,
3.   Total cost of replacing fence                           $9442
     (Line 1 x Line 2)
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                                LANDFILLS
                  WORKSHEET G - PROFESSIONAL CERTIFICATION
 1.    Number of person-hours required for inspections
 2.    Cost per person-hour
 3.    Total costs of independent professional engineer
      certification (Line 1 x Line 2)
 4.    Number of technical hours required for administrative
      duties
 5.    Person-hour costs for technical administrative duties
 6.    Total administrative costs for technical labor
      (Line 4 x Line 5)
 7.    Number of clerical hours required for administrative
      duties
 8.    Person-hour costs for clerical administrative duties
 9.    Total administrative costs for clerical labor
      (Line 7 x Line 8)
10.    Total administrative costs (Line 6 + Line 9)
11.    Total certification costs (Line 3 + Line 10)
80 hrs,
$75
$6000

8 hrs.

$30
$240

5 hrs.

$8
$40
                                   9-73

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                                LANDFILLS
              WORKSHEET H - TOTAL COSTS OF CLOSURE INCLUDING
                    ADMINISTRATION AND CONTINGENCIES
 1.   Cost of disposing of inventory (From Worksheet A)       $ 24,000
 2.   Cost of decontaminating the surface and ancillary       $  2,850
      facilities (From Worksheet B)
 3.   Cost of placing the final cap (From Worksheet C)        $ 77,828
 4.   Cost of planting final vegetation (From Worksheet D)    $  7,425
 5.   Cost of ground-water monitoring (From Worksheet E)      $  2,195
 6.   Cost of fence maintenance (From Worksheet F)            $  9,442
 7.   Cost of professional certification (From Worksheet G)   $  6,280
 8.   Total of Line 1 through Line 7                          $130,020
 9.   Administration                                          $ 19,503
10.   Contingencies                                           $ 19,503
11.   Total costs of closure (Line 8 + Line 9 + Line 10)      $169.026
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9>5                      EXAMPLE - INCINERATORS

     A 12-acre incinerator facility has bulk storage facilities for 120,000
gallons of slop oil, 120,000 gallons of phenolic wastewater, and 1,000,000
gallons of organic sludge.  Waste is also delivered in 55-gallon drums; a
maximum of 600 drums may be stored at the facility.  In addition to these
delivered wastes, the facility normally contains an inventory of 50 drums
of non-combustible ash from the incinerator.
     The incinerator is designed to operate at 16 gpm with the following
feed mixture: 4 gallons of slop oil, 4 gallons of wastewater, and 8 gallons
of sludge (a 1/1/2 ratio).  The total operating horsepower of the incinerator
(including pollution control equipment in the form of a caustic scrubber
used to remove chlorinated compounds emitted from the slop oil) is 350 HP.
The following worksheets are based on this facility description.
                                   9-75

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         SAMPLE CLOSURE COST ESTIMATING WORKSHEETS: INCINERATORS

A.   Characterizing the Waste Inventory
     Worksheet A is used to describe each waste accepted at the site.  For
the example, worksheets must be prepared for each of the following wastes:
slop oil, phenolic wastewater, and biological treatment sludges.  For each
waste product accepted, the following information is required:
     1.  Describing the waste:  Describing the origin and general nature
of the waste.
     2.  Chemical composition:  Chemical composition should be expressed
in weight percents for major components and parts per million (ppm) for
trace components.  This information should be readily available to the
operator from the bill of-.lading for each waste shipment.
     3.  Physical state of the waste:  This describes whether the waste is
a liquid, solid, or mixture.  This information is utilized in making,estimates
of solid residues requiring disposal (Worksheet B).
     4.  Heat of combustion of the waste:  The heat content (expressed in
BTU/lb., or BTU/gal.) of the waste products.  This information is used in
determining auxiliary fuel requirements (if any) on Worksheet C.
     5.  Specific gravity of the waste:  The specific gravity of the waste
at 60°F referenced to water at 60 F is used in the example problem.
     6.  Closure inventory:  For the example, it has been assumed that the
operator has identified from experience that the maximum inventory he has
ever had stored on-site was a 14-day backlog.  We will assume that this
inventory is comprised of the total components: 224 drums of slop oil
(12,320 gallons), 224 drums of phenolic wastewater (12,320 gallons) and
152 drums of sludges (8,360 gallons); the bulk storage tanks contain 28,000
gallons of slop oil, 28,000 gallons of phenolic wastewater, and 233,560
gallons of organic sludges.  Under these conditions, the incinerator will
be able to treat its inventory through seven days of burning its optimum
feed mixture, and seven days of burning sludges alone (through the addition
of auxiliary fuels).
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B.   Treating the Inventory
     It is assumed that the inventory on-hand at the time of closure will
be incinerated on-site.  All equipment necessary for the operation of the
incinerator is assumed to be in complete working order.
     1.  Time required for treating the inventory:  It will require 336 hours
(322,560 gallons of waste -r 960 gallons throughput per hour).  If it is
further assumed that the incinerator is on-stream 90% of the time, the total
time required for treating on-site inventory is 373 hours.
     2.  Manpower requirements for treating the inventory:  The total number
of personnel required to operate this facility (including plant operators,
equipment operators, guards, maintenance persons, and laboratory personnel)
is estimated as six.  Therefore, total man-hour requirement for treating
the inventory is 2238 hours.
     3.  Cost of manpower:  The average hourly wage rate of a plant operator
(including fringe benefits and labor burdens) is assumed to be $20.
     4.  Total costs of operating labor during inventory treatment (Line 2
x Line 3):  Given the above assumptions, labor costs for this phase of
closure are $44,760.
     5.  Fuel requirements for treating the inventory:  These represent both
the cost of utilities consumed in order to treat the waste inventory, plus
any auxiliary fuels which had to be purchased.  Each of these items is
separately costed below.
     6.  Electricity requirements for treating the inventory:  The inciner-
ator is actually in operation for 336 hours.  Electricity requirements for
                                       KW
the example are equal to 350 HP x .746 T~ x 336 hours =• 87,730 kwh.
     7.  Costs of electricity:  Electricity is assumed to be available at
a cost of $.06/kwh.
     8.  Total costs of electricity (Line 6 x Line 7):  Total electricity
costs for the example are $5264.
     9.  Auxiliary fuel requirements:  During the first 168 hours of inven-
tory treatment, the incinerator will be receiving an input feed of 25% slop
oil, 25% phenolic wastewater, and 50% organic sludges.  This feed has a
heat value of 2900 BTU/lb. and will burn autogenously.  During the remaining
168 hours, the feed will be comprised entirely of sludges, with a heat
value of 700 BTU/lb.; this mixture does require auxiliary fuel inputs .
                                   9-77

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     10. type of auxiliary fuel used:  It is assumed that #6 fuel oil is
used as the auxiliary fuel.
     11. Quantity of fuel required:  Using engineering analysis, and
assuming an average heat value of 154,000 BTU/gal. for fuel oil, total
auxiliary fuel requirements are estimated at 10,456 gallons.
     12. Cost of auxiliary fuel:  It is assumed that #6 fuel oil is available
to the operator at $.90 per gallon.
     13., Total cost of auxiliary fuels (Line 11 x Line 12):  The total
cost of auxiliary fuel inputs is $9410.
     14. Total fuel costs (Line 8 + Line 13):  Total fuel costs are $14,674.
     15. Chemical requirements:  This category includes all chemicals,
catalysts, adsorbents, and other supplies consumed during inventory treat-
ment.  In the example, the only chemical required is the caustic consumed
during flue gas scrubbing of chlorine entrained in the incinerator waste
stream.
     16. Type of chemicals used:  It is assumed that the caustic will be
purchased as a 50% solution.
     17. Quantity of chemicals required:  There are 40,320 gallons of slop
oil in the waste inventory assumed to be present at the time of closure.
This is equivalent to 319,334 Ibs. of slop oil (40,320 x .95 specific
gravity of slop oil x 8.34 Ibs./gal. water).  Since the chlorine content
of the slop oil is assumed to be no greater than 3 percent, the maximum
quantity of chlorine to be scrubbed is 9,580 Ibs. (2.70 moles).  Assuming
that 1 mole of NaOH is required to neutralize 1 mole of chlorine, 270 moles
x 40 Ibs. NaOH/mole = 10,800 Ibs. NaOH consumption.
     18. Cost of chemicals required:  Caustic is assumed to cost $.08257
dry Ib.
     19. Total cost of chemicals (Line 17 x Line 18):  The total cost of
chemicals consumed during inventory treatment is $891.
     20. Disposing or treating residues -generated during inventory treatment:
The residue generated during inventory treatment is a powdery solid, inciner-
ator ash.  The ash has a ap«c±fic gravity of 2.5.
     21. Amount of residue on-s"ite after treating the inventory:  There
are 50 55-gallon drums of ash stored on-site at the point of closure (each
weighing 1150 Ibs., for a total of 57,500 Ibs.).  In addition, residues
                                     9-78

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are generated by processing the waste inventory.  The sludges incinerated
in the example are assumed to be 10 percent solids; one-third of the solids
are assumed to be non-combustible.  The slop oil and wastewaters processed
by the incinerator produce no ash.  Therefore, the amount of new residue
generated * (total amount of sludge in inventory times specific gravity
of the non-combustible portion of the materials times the portion of the
sludge that is non-combustible), or:
         241,920 x (2.5 x 8.34) x .0333 = 167,968 Ibs.
Total residue to be disposed of is equal to 167,968 Ibs. and 57,500 Ibs. -
225,468 Ibs.
     22. Method of disposing of ash:  It is assumed that the incinerator
ash is put into drums and transported to a secure landfill.  The residue
generated during inventory treatment can be placed in 146 drums, making
the total number of drums to be disposed of 196.
     23. Unit costs of disposing of residue:  The costs of disposing in
a landfill are assumed to be $50/drum, according to industry specialists.
     24. Total costs of disposing of residue (Line 21 x Line 23):  Total
costs for the sample case are $9800.
     25. Costs of hauling residue to landfill for disposal:  In the example,
it is assumed that the nearest landfill that will accept the drummed
residue is 50 miles away, and that trucks with a carrying capacity of 40
drums are rented at an hourly cost of $60.  At a speed of 40 mph, and
assuming four hours for loading/unloading each trip,  the total hauling
costs are estimated at $1950.
     26. Total cost of treating and disposing of inventory (sum of Lines
4, 14, 19, 24, and 25):  Given the above assumptions, the total cost of
inventory disposal will be $72,075.

C.   Decontaminating the Facility
     In order to completely decontaminate the incinerator facility, the opera-
tor must see to it that all storage tanks and liquid waste feed lines are
cleaned, that wastewaters from the cleaning process are properly disposed
or treated, that all equipment structures and containers left on-site are
decontaminated, and that all contaminated soil is removed properly.  These
various activities are individually cos ted below.
                                   9-79

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Tank Cleaning
     1.   Storage tank cleaning:  The total volume of storage capacity to
be cleaned is 1,240,000 gallons (120,000 gallons of slop oil storage,
120,000 gallons of phenolic wastewater storage, and 1,000,000 gallons of
organic sludge storage).
     2.  Method used:  The cleaning method selected for the sample case
is steam-cleaning.
     3.  Unit cost of cleaning:  Renting equipment, labor, and operating
costs for 1600 gal./hour of cleaning equipment are assumed to be approxi-
mately $.02/gal. of capacity cleaned, based on information from the Means
construction cost guide.
     4.  Total costs of storage tank cleaning (Line 1 x Line 2):  Total
costs of steam-cleaning the storage facility are $24,800, given the above
assumptions.
     5.  Cleaning residue generation:  According to closure guidelines for
waste treatment sites issued by the Texas Department of Water Resources,
the amount of contaminated washwaters produced by steam-cleaning can be
assumed to be equal to .125 times the volume of the tank being cleaned.
     6.  Quantity of cleaning residue generated (Line 1 x Line 5):
155,000 gallons of contamined washwater are generated in the example.
     7.  Method of disposing of residue:  In the sample case, residues are
assumed to be transported by tank truck to a surface impoundment for
evaporation.
     8.  Unit costs for disposing of residues:  Based on waste disposal
industry estimates, it will cost $.05/gal. to dispose of residues in an
impoundment.
     9.  Total costs for disposing of residues (Line 6 x Line 8):  Total
costs of cleaning residue disposal, given these assumptions, are $7750.
    10.  Hauling costs for residues:  In the example, hauling cost esti-
mates are based on the following assumptions - the distance between the
incinerator and the surface impoundment is 100 miles one-way, a 7000-gallon
trailer is used, the average trip speed is 40 mph, and the hourly rental
cost of truck and driver is $60.  The cost of one round trip is $300.
    11.  Number of trips required:  The number of trips required for the
case is 23.

                                   9-80

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     12. Total hauling costs for residues (Line 10 x Line 11):  The hauling
costs for residue disposal are estimated at $6900.

Decontaminating the Facility
     13. Flush out liquid waste feed lines:  The estimated cost of flush-
ing out all liquid residues from feed lines on the facility (before the
storage areas and incinerators are cleaned) is assumed to be roughly one-
eighth of the costs of tank cleaning, or $3000.
     14. Pump out and backfill sumps:  Sumps are to be decontaminated to
prevent the possibility of rain water accumulating and contaminating these
portions of the facility.  The estimated costs of this activity are
$2000.
     15. Removing contaminated soils:  Because of spills and other
accidental releases, certain areas of the waste disposal site such as
the dikes in areas around storage tanks may be contaminated.  We have
assumed in this example problem that 2.5 percent of the area of the site
(exclusive of reservoirs, ponds, and basins) is contaminated.
         Contaminated area = .025 x  12 acres x 4840 sq. yd./acre
                           » 1452 sq. yds.
     16. Depth of soil removal:  For this example, the assumed depth of
soil removal is one foot.
     17. Total amount of soil removed (Line 15 x Line 16):  The total
amount of soil removed in this example is (1452 x .333), or 484 cu. yds.
     18. Unit cost of removing soil:  Costs of removing soil (including
equipment rental) are estimated at $1.60/cu. yd.
     19. Total cost of soil removal  (Line 17 x Line 18):  Given the above
assumptions, the cost of removing the contaminated soil from the inciner-
ator site is $774.
     20. Costs for disposing of contaminated soils:  The contaminated soil
is assumed to be disposed in a sanitary landfill.  Based on current esti-
mates, the soil can be landfilled at a cost of $30/ton.
     21. Total cost of disposing of soil (Line 17 x Line 20):  The cost
of disposing of the contaminated soil is $14,520.
     22. Hauling costs for contaminated soil:  In- this example, the
nearest landfill is assumed to be 50 miles away, the truck used for hauling

                                   9-81

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has a carrying capacity of 44,000 Ibs., and is rented at a hourly cost
of $60.                                                                        m
     23. Number of trips required:  Assuming an average speed of 40 mph,
22 trips will be required.
     24. Total hauling costs for contaminated soil (Line 22 x Line 23):
Given the above assumptions, the total costs for hauling the contaminated
soil are $3300.
     25. Total costs of decontaminating the facility (sum of Lines 4, 9,
12, 13, 14, 19, 21, and 24):  The total costs of decontaminating the
sample incinerator are $63,044.

D.   Monitoring
     1.  Cost of air sampling during inventory treatment:  In order to
ensure that the incinerator remains in compliance with Clean Air Act
regulations during the closure period, it was assumed that daily sampling
cost of $25 are incurred while the incinerator is operating.
     2.  Number of samples required:  The inventory treatment phase of
closure is estimated to take 16 days at the sample site.                       ^
     3.  Total costs of monitoring (Line 1 x Line 2):  Given the above         ^
assumptions, monitoring costs will be equal to $400.

E.   Professional Certification
     1.  Number of person-hours required for inspections:  It is assumed
that 20 hours are required for periodically inspecting all aspects of
incinerator closure.
     2.  Cost per person-hour:  In this case, assume that a registered
independent professional engineer may be hired at a cost of $75 per hour.
     3.  Total costs of independent professional engineer's time (Line 1
'x Line 2):  This yields a total cost of $1500 for the independent profes-
sional engineer.
     4.  Number of technical hours required for administrative duties:
Assume that eight hours are required from the owner's or operator's staff for
administrative duties connected with employing an independent professional
engineer.


                                   9-82

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     5.  Person-hour costs for technical administrative duties:  It is
assumed that the total fully-loaded costs for the owner's or operator's staff
are $30 per hour.
     6.  Total administrative costs for technical labor (Line 4 x Line 5):
Given the above assumptions, the total administrative costs for technical
labor are $240.
     7.  Number of clerical hours required for administrative duties:
Assume that five hours of clerical time are required for the necessary
typing and certifications.
     8.  Person-hour costs for clerical administrative duties:  Fully-
loaded costs of clerical time are assumed to be $8.
     9.  Total administrative costs for clerical labor (Line 7 x Line 8):
Given the above assumptions, total clerical costs are $40.
    10.  Total administrative costs (Line 6 + Line 9):  Summing technical
and clerical labor, the administrative costs are $280.
    11.  Total certification costs (Line 3 + Line 10):  The total costs for
certification, including engineer's fees and administrative costs, are
$1780.

F.   Total Costs Including Administration and Contingencies
     Line 1 through 4:  These lines simply require the transfer of the
cost information supplied in Worksheets 3 through E.
     5.  Preliminary closure cost estimate (sum of Lines 1 through 4):
For the sample facility, total worksheet costs are qual to $137,299.
     6.  Administration:  The costs for administration, which include
insurance, taxes, and supervision and administration not included else-
where, are assumed to be 15 percent of Line 5.
     7.  Contingencies:  A provision for contingencies of 15 percent of
Line 5 has been included.
     8.  Total costs of closure (Line 5 + Line 6 + Line 7):  The total
costs of closure, including administration and contingencies, for the
sample incinerator are $178,489.
                                   9-83

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                              INCINERATORS
                 WORKSHEET A - CHARACTERIZING THE WASTE (#2)

This worksheet should be used to describe each waste accepted at the facility.

1.   Description of .the waste:
         Phenolic wastewater
2.   Chemical composition of the waste:
         1000 ppm phenols
3.   Physical state of the waste:
         Liquid
4.   Heat of combustion of the waste:
         0
5.   Specific gravity of the waste:
         1.0
6.   Closure inventory:
         40,320 gal.
                                   9-84

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                              INCINERATORS
                WORKSHEET A - CHARACTERIZING THE WASTE (#3)

This worksheet should be used to describe each waste accepted at the facility,

1.   Description of the waste:
         Waste activated sludge
2.   Chemical composition of the waste:

3.   Physical state of the waste:
         Mixture (suspension) - 10% solids, 90% water
4.   Heat of combustion of the waste:
         700 BTU/lb.
5.   Specific gravity of the waste:
         1.06
6.   Closure inventory:
         241,920 gal.
                                     9-85

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                               INCINERATORS
                   WORKSHEET B - TREATING THE INVENTORY
 1.   Time required for treating the inventory
 2.   Manpower requirements for treating the inventory
 3.   Unit cost of labor
 4.   Total cost of labor - treating the inventory
      (Line 2 x Line 3)
 5.   Fuel requirements
 6.   Electricity requirements
 7.   Unit cost of electricity
 8.   Total costs of electricity (Line 6 x Line 7)
 9.   Auxiliary fuel requirements

10.   Type of fuel used
11.   Quantity of fuel required
12.   Unit cost of fuel oil
13.   Total cost of auxiliary fuels
      (Line 11 x Line 12)
14.   Total fuel costs for treating inventory
      (Line 8 + Line 13)
15.   Chemical requirements
16.   Type of chemicals used
17.   Quantity of chemicals used
18.   Unit cost of chemicals
19.   Total cost of chemicals (Line 17 x Line 18)
20.   Residues generated during inventory treatment
21.   Amount of residue generated

22.   Method of treatment
23.   Unit cost of disposing of residue
24.   Total costs of disposing of residue
      (Line 21 x Line 23)
25.   Hauling costs for disposing of residue
26.   Total costs of treating and disposing of
      inventory (sum of Lines 4, 14, 19, 24, and 25)
                                      9-86
373 hours
2238 man-hours
$44,760

Yes
87,730 kwh
$.06/kwh
$5264
Yes , for input
feed B
#6 fuel oil
10,456 gal.
$.90/gal.
$9410

$14,674

Yes
Caustic, 50% solution
10,800 Ibs.
$.0825/lb.
$891
Incinerator ash
225,468 Ibs.
(196 drums)
Landfill
$50/drum
$9800

$1950
$72,075

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                               INCINERATORS
                WORKSHEET C - DECONTAMINATING THE FACILITY
 1.   Volume to be cleaned
 2.   Method used
 3.   Unit costs of cleaning
 4.   Total costs of tank cleaning (Line 1 x Line 2)
 5.   Cleaning residue generation rate
 6.   Amount of residue generated (Line 1 x Line 5)
 7.   Method of disposal
 8.   Unit cost for disposing of residue
 9.   Total costs for disposing of residue
      (Line 6 x Line 8)
10.   Unit cost for hauling residues
11.   Number of trips required
12.   Total costs of hauling residues
      (Line 10 x Line 11)
13.   Cost of flushing liquid waste feed lines
14.   Cost to pump out and backfill sumps
15.   Amount of contaminated soil area
16.   Depth of soil removal
17.   Total amount of soil removed (Line 15 x Line 18)
18.   Unit cost of removing soil
19.   Total cost of removing soil (Line 17 x Line 18)
20.   Costs for disposing of contaminated soils
21.   Total cost of disposing of soil (Line 17 x Line 20)
22.   Unit costs of hauling contaminated soils
23.   Number of trips required
24.   Total cost of hauling soils (Line 22 x Line 23)
25.   Total costs of decontamination (sum of Lines
      4, 9, 12, 13, 14, 19, 21, and 24)
1,240,000 gal.
Steam-cleaning
$.02/gal. capacity
$24,800 .
.125 x volume of tank
155,000 gal.
Surface impoundment
$.05/gal.
$7750

$300/trip
23
$6900

$3000
$2000
1452 sq. yds.
1 ft.
$774
$1.60/cu. yd.
$774
$30/ton
$14,520
$150
22
$3300
$63.044
                                   9-87

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                              INCINERATORS
                        WORKSHEET D - MONITORING
1.   Cost of air sampling                                $25/day
2.   Number of samples required                          16
3.   Total costs of air monitoring (Line 1 x Line 2)     $400
                                       9-88

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                               INCINERATORS
                 WORKSHEET E - PROFESSIONAL CERTIFICATION
 1.    Number of person-hours required for inspecting the     20
      facility
 2.    Cost per person-hour                                   $75
 3.    Total costs of independent professional engineer       $1500
      certification (Line 1 x Line 2)
 4.    Technical hours required for administrative            8 hrs,
      duties
 5.    Person-hour costs for technical administrative duties  $30
 6.    Total administrative costs for technical labor         $240
      (Line 4 x Line 5)
 7.    Number of clerical hours required for administrative   5 hrs,
      duties
 8.    Person-hour costs for clerical administrative duties   $8
 9.    Total administrative costs for clerical labor          $40
      (Line 7 x Line 8)
10.    Total administrative costs (Line 6 + Line 9)
11.    Total certification costs (Line 3 + Line 10)
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                             INCINERATORS
  WORKSHEET F - TOTAL COSTS INCLUDING ADMINISTRATION AND CERTIFICATION
1.   Costs of treating and disposing inventory (From
     Worksheet B)
2.   Costs of decontaminating the facility (From
     Worksheet C)
3.   Costs of monitoring (From Worksheet D)
4.   Costs of professional certification (From
     Worksheet E)
5.   Estimated basic costs of closure (sum of Lines
     1, 2, 3, and 4)
6.   Administration
7.   Contingencies
8.   Total costs of closure
$ 72,075

$ 63,044

$    400
$  1,780

$137,299

$ 20,595
$ 20,595
$178.489
                                   9-90

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9.6          EXAMPLE - MULTIPLE PROCESS FACILITY WITH TANKS
                         AND SURFACE IMPOUNDMENTS

     A 2-acre hazardous waste treatment and storage facility has storage
tanks for 60,000 gallons of waste solvents and 10,000 gallons of slop
oil.  Waste is received at the facility both from tank trucks and in
55 gallon drums; the facility has a maximum storage capacity of 200
drums.  There are two treatment processes undertaken at the facility.
There is a 30,000 gallon (50' x 20' x 4') concrete-lined surface
impoundment used for the gravity separation of oily wastes into solvent,
slop oil, and sludge phases.  The normal composition of the oil wastes
accepted is 80 percent solvent, 15 percent oil, and 5 percent sludge.
There is a 30,000-gallon clay-lined surface impoundment (also 50' x 20'
x 4') for solidifying pickling liquor wastes.  A storage pile holds
up to 8,000 cu. ft. of solidified pickling wastes; it is surrounded
by a clay-lined surface impoundment that collects drainage and run-off.
                                   9-91

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   SAMPLE CLOSURE COST ESTIMATING WORKSHEETS: MULTIPLE PROCESS FACILITY

A.   Characterizing the Waste
     Worksheet A  is used to describe each waste accepted at the facility.
For example, separate worksheets must be prepared for each of the following
wastes: oily wastes and pickling liquor wastes (the two types of wastes
processed at the storage facility) and the three end products of the treat-
ment actions performed (waste organic solvents, slop oil, and solidified
pickling liquor wastes).  For each waste product specified, the following
information is required:
     1.  Describing the waste:  Describe the origin and general nature
of the waste.
     2.  Chemical composition:  Chemical composition should be expressed
in weight percents for the various major components, and in parts per million
(ppm) for any trace components.   This information may be readily available
to the operator from the bill of lading for each waste shipment.
     3.  Physical state:  This describes whether the waste is a liquid,
solid, or mixture.  This information is used in making estimates of solid
residues requiring disposal (Worksheet B).
     4.  Heat of combustion of the waste:  Represents the heat content
(expressed in BTU/lb. or BTU/gal.) of the waste products.  The information
is used to determine auxiliary fuel requirements if the waste is to be
disposed of through incineration.
     5.  Specific gravity of the waste:  The specific gravity of the waste
at 60 F referenced to water at 60 F.
     6.  Closure inventory:  The operator must identify the maximum quan-
tity of each waste that can be present at the facility in storage tanks,
drums, or surface impoundments,  during any point in the facility's active
life.  In the example, it is assumed that there are times in which the stor-
age capacity of this facility is completely utilized.  This would therefore
represent the maximum inventory for developing the closure cost estimate.
In the sample case, the closure inventory would consist of 65,500 gallons
of waste solvents, 10,000 gallons of slop oil, 35,000 gallons of oily waste,
30,000 gallons of pickling liquor waste and 8,000 cu. ft. of solidified
pickling wastes.
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B.   Treating Inventory
     1.  Waste inventory:  As noted in the waste characterization section
of this example, the sample facility is assumed to have the following waste
products on-site at the time of disposal: 35,500 gallons of oily waste,
30,000 gallons of pickling liquor wastes, 65,500 gallons of recovered waste
solvent, 10,000 gallons of recovered slop oils, and 8,000 cu. ft. of solidi-
fied pickling wastes.
     2.  Methods of treatment or removal:  These materials will be removed
of in a variety of ways, as indicated below:
         a.  Solvents - it is assumed that the facility can find other manu-
facturing/commercial establishments that will use the waste solvents (which
have a BTU content of 135,000 BTU/gal.) as boiler fuel.
         b.  Slop Oils - pumped out of storage and hauled to an incinerator.
         c.  Oily Wastes - placed in surface impoundment for separation
into its component parts.  Solvents and slop oils recovered from this pro-
cess are disposed of in the same manner as (a) and (b) above.  Sludges left
in the basin are to be dredged, stabilized.and hauled to a landfill.
         d.  Pickling Liquor Wastes - solidify with cement and transfer
the resulting solid waste to a landfill.
         e.  Solidified Pickling Liquor Wastes - transfer to a land-
fill.
         Since treatment of inventory categories (c)  and (d) will generate
additional waste products in categories (a), (b) and  (e), these preliminary
processing phases will be discussed first.

Disposing of Oily Waste
     3.  Composition of oily wastes:  It is assumed that the normal compo-
sition of the oily wastes is 80 percent solvent, 15 percent slop oil, and
5 percent sludge.
     4.  Amount of wastes produced after settling:  Using this percentage
mix, settling out the inventory of oily wastes will produce 28,400 gallons
of solvent, 5,325 gallons of slop oil, and 1,775 gallons of sludge.
     5.  Sorbent requirements:  It is assumed that the sludge will be mixed
with an equal volume of sorbent material, with a specific gravity of 1.8.
The specific gravity of the sludge is estimated at 1.2.
     6.  Cost-of sorbent:  It is assumed that sorbent material is available
on-site for no cost.
                                    9-93

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     7.  Amount of residue generated:  After stabilization, approximately
22 tons of residue will need to be landfilled.
     8.  Unit cost of disposing of residue:  It is assumed that a land-
fill will charge $50/ton to dispose of the stabilized residues.
     9.  Total costs of disposing of residue (Line 7 x Line 8):  Given
these assumptions, the total cost of disposing of facility sludge resi-
dues will be $1100.
    10.  Costs of hauling; residue:  It is assumed that the nearest land-
fill is 100 miles one-way from the site.  Trucks with a 44,000-lb.
capacity can be rented at a cost of $60 per hour (including driver);
the average traveling speed of the truck is 40 mph.  For one round trip,
the cost of residue hauling is $300.
    11.  Number of hauls required:  With 22 tons of waste (line 7), only
one trip by a 44,000 Ib. capacity truck will be required.
    12.  Total cost of hauling residue (Line 10 x Line 11):  Given
these assumptions, the total cost of hauling residue is $300.
    13.  Cost of disposing of oily waste (Line 6 + Line 9 + Line 12):
The total cost of disposing of oily waste is then the sum of sorbent
material costs, costs of disposal, and costs of hauling for a total of $1400.

Disposing of Pickling Liquor Waste

    14.- In order to solidify the pickling liquor wastes in the closure
inventory, the waste must be mixed with cement.  It is estimated that
one sack (94 Ibs/sack) of cement will solidify 10 gallons of waste.
    15.  Amount of cement required:  To dispose of on-site inventory,
3,000 sacks of cement (282,000 Ibs.) will be required.
    16.  Cost of cement:  Cement is estimated to cost $2.50/sack.
    17.  Total cost of materials (Line 15 x Line 16):  Given the above
assumptions, total material  costs for solidifying the inventoried
pickling liquor waste are $7,500.
    18.  Total amount of residues produced:  Given a specific gravity
of pickling wastes of 1.05, and the proportions of cement to waste
assumed, the total solid residues produced by inventory disposed is
272.4 tons.

                                 9-94

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          Liquor » 30,000 gal x 1.05 S.G. x 8.34  (water weight) =
                   262,800 Ib.
          Cement - 3,000 sacks x 94 Ibs/sack = 282,000 Ibs.
                   262,000 Ibs + 282,000 Ibs - 544,800 Ibs -
                   272.4 tons
     19.  Other on-site residues:  Waste category  (e) represents
previously solidified pickling wastes stored on-site.  It is assumed
that there is 8,000 cu. ft. of this material currently in storage, and
that the material weighs approximately 135 Ib/cu.  ft  (similar to a
mortar-like cement).  Therefore, the total weight  of  this residue
would be 1,080,000 Ibs. (540 tons).
     20.  Total amount of pickling residue (Line  18 + Line 19):  Total
solid residues from treatment of the pickling wastes  are 812.4 tons.
     21.  Unit cost of disposing of residue:  As  in Line 8 above, it is
assumed that a landfill will charge $50/ton to dispose of such residues.
     22.  Total cost of disposing of residue (Line 20 x Line 21):  Total
disposal costs are estimated to be $40,620.
     23.  Costs of hauling residues:  The costs and method of hauling
residues are the same as Line 10 above.
     24.  Number of hauls required:  Given truck  capacity of 44,000 Ibs.
(22 tons), it will take 37 round trips to haul the solidified pickling
wastes.
     25.  Total cost of hauling residues:  Given  the  above assumptions,
the total hauling costs will be $11,100.
     26,  Cost of disposing of pickling liquor waste  (Line 17 + Line 22
+ Line 25):   The total cost of disposing of pickling  liquor waste is
then the sum of costs of materials, residue disposal  and hauling, for a
total of $59,220.
     27.  Amount of solvent on-site:  Including the solvents recovered
during the settling of inventoried oily waste, the total inventory of
waste solvents at the sample facility are 60,000  gal. (storage tank) +
5,500 gal. (drums)  + 28,400 gal. (surface impoundment) = 93,900 gal.
     28.  Method of disposal:  It is assumed that  the waste solvents can
be provided to manufacturers as a boiler fuel.
                                 9-95

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     29.  Cost of disposal:  It is assumed that the users of the solvents
will pay the costs of pumping and hauling the solvents to their facilities.
No additional credit is awarded to the owner/operator of the tank facility.

Treating Slop Oil

     30.  Amount of slop oil on-site:  Including the slop oils recovered
during the settling of inventoried oily waste, the total inventory of
slop oils are 10,000 gal. (storage tank) + 5,325 gal. (surface impound-
ment) = 15»325 gal.
     31.  Method of treatment:  It is assumed that the slop oils will he
trucked to an incinerator.
     32.  Cost of treatment:  The estimated fee paid to the incinerator
for treating the wastes is $0.60/gallon.
     33.  Total costs of treatment (Line 30 x Line 32):  Given the above
assumptions, it will cost $9,195 to treat the slop oil inventory.
     34.  Costs of hauling:  It is assumed that the nearest incinerator
is 50 miles away, that Che wastes will be transported in a 7,000-gallon
capacity truck, at an average speed of 40 mph.  The hourly rental cost
for truck and driver is $60.
     35.  Number of hauls required:  Given trailer capacity, it will
require three trips to haul the slop oils to the incinerators.
     36.  Total costs of hauling:  Given the above assumptions, hauling
costs are estimated at $450.
     37.  Total costs of treating slop oil (Line 33 + Line 36):  The total
costs of treating slop oil are then the sum of the costs of disposal and
hauling, for a total of $9,645.
     38.  Total costs of disposing of inventory (sum of Lines 6, 9, 12,
17, 22, 25, 29, 33, and 36):  The total costs of the above activities
are estimated to be $70,265.
                                9-96

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C.   Decontaminating the Facility

Tank Cleaning

     1.  Cleaning method:   In this example,  the  storage  tanks  are
steam cleaned.
     2.  Volume:  In the sample case, there  are  60,000 gallons of
solvent storage capacity and 10,000 gallons  of oil storage capacity
to be cleaned, for a total of 70,000 gallons.
     3.  Unit cleaning costs:  For a 2,000 gallon-per-hour steam cleaning
unit (capable of washing a  16,000-gallon area of storage capacity/hour),
costs of equipment rental,  labor, and operation  are  equal to $.02/gallon
of capacity cleaned.
     4.  Total costs of steam cleaning  (Line 2 x Line 3):  Total cleaning
costs for the storage tanks is $1400.
     5.  Type and quantity of residues  generated:  Steam cleaning
generates residues in the form of contaminated washwaters.  The rate of
residue generation is 1 gallon of waste/8 gallons of tank volume.  In
the example, total residues are 70,000  * 8,  or 8750  gal.
     6.  Method of disposal:  It is assumed  that the residues  are hauled
to a surface impoundment and evaporated.
     7.  Cost of disposal:  Impoundment disposal of  washwaters is
estimated to cost $.05/gallon.
     8.  Total cost of disposal (Line 5 x Line 7):   Costs of disposing
of these cleaning residues will be $438.
     9.  Cost of hauling cleaning residues:  For one round trip, the
cost of hauling residues is $600.  The  cleaning  residues will be hauled
in a 7,000-gallon tank truck, with an average truck  speed of 40 mph.
The hourly rental cost for truck and driver  is $60;  the  nearest
available surface impoundment is assumed to  be 200 miles away.
    10.  Number of hauls required:  Given the assumption on residue
generation and truck capacity, two trips will be required, at  $6007trip.
    11.  Total costs of hauling:  Total hauling  costs are $1200.
    12.  Total costs:  The sum of the costs of steam cleaning, disposal
and hauling yields a total of $3038.
                                 9-97

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Decontaminating the Impoundment

     13.  Cleaning method for Impoundment 1:  It is assumed that the
concrete-lined impoundment will be sandblasted.
     14.  Area of concrete impoundment to be cleaned:  The area requiring
sandblasting, based on the sample facility description, is equal to the
base area  (50' x 20', or 100 sq. ft.) plus the area of the site
walls (2' x 50' x 4' + 2' x 20' x 4', or 560 sq.  ft.), for a total of
1560 sq. ft.
     15.  Costs of sandblasting:  A 6 cu. ft. capacity compressor will
be used in the sample estimate.  The unit rents for a $100/week, and
costs $1.75/hour to operate; labor costs are estimated at $20/hour.
The unit can clean 40 sq. ft. of concrete/hour.  Consequently, sand-
blasting costs are estimated at $.60/sq. ft.
     16.  Total costs of sandblasting (Line 14 x Line 15):  Sandblasting
costs are estimated to be $936.
     17.  Type and quantity of residue generated:  The residues will
consist of contaminated sands.  It was assumed that 4000 Ibs. (2 tons)
of sand residue will be generated.
     18.  Unit costs of disposal:  The sands will be landfilled at a
disposal cost of $50/ton.
     19.  Total costs of disposal (Line 17 x Line 18):  Total disposal
costs will be equal to $100.
     20.  Cleaning method for Impoundment 2:  All contaminated cla'ys
from the clay-lined impoundment will be removed and hauled to a landfill.
     21.  Area of clay impoundment to be decontaminated:  Since the dimen-
sions of this impoundment are the same as those of the concrete-lined
impoundment discussed above, the surface area to be contaminated is the
same as that estimated in Line 14 of this worksheet, or 1560 sq. ft.
     22.  Amount of clay removed:  It is assumed that the clay in the
pickling liquor impoundment has been contaminated to a depth of one
foot.  Therefore, 1560 cu. ft. of clay, or 57.8 cu. yds., must be
removed.
                                9-98

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     23.  Unit cost of removing clay:  Clay removal will be. performed
with a backhoe.  Including costs of equipment rental and labor, the
costs of removing the clay is estimated to be $1.60/cu. yd.
     24.  Total costs of removing clay (Line 22 x Line 23):  Given the
above assumptions, the costs of removing the soil are $92.
     25.  Disposing of contaminated clays:  Clays will be hauled to a
landfill for disposal.  The costs of disposal are estimated to be
$30/cu. yd.
     26.  Total costs of disposal (Line 22 x Line 25):  The total costs
of disposal are $1734.

Removing Soil and Miscellaneous Activities

     27.  Removing contaminated soils:  Because of spills and other
accidental releases, certain areas of the waste disposal facility, such
as diked-in areas around storage tanks will be contaminated.  It is
assumed for the sample facility that 2.5 percent of the total site area
is contaminated.
          Contaminated area « 2 acres x 4840 sq. yd./acre x .025
             rate of contamination - 242 sq. yd.
     28.  Amount of soil removed:  The depth of soil removal required
to remove all hazardous contaminants is assumed to be 1 foot.  Thus,
the total amount of soil removed - 242 sq. yd. x .33 yd. =80.7 cu. yds.
     29.  Unit cost of removing soil:  As in Line 23, removing soil can
be accomplished at a cost of $1.60/cu. yd.
     30.  Total cost of removing soil (Line 28 x Line 29):  Total cost
of removing soil is $129.
     31.  Disposing of contaminated soils:  Contaminated soils are also
hauled to a landfill, where they may be disposed at a cost of $30/
cu. yd.
     32.  Total costs of disposal (Line 28 x Line 31):  Given the above
assumptions, disposing of soils will cost $2421.
                                9-99

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     33.  Hauling costs for decontamination wastes:  The wastes described
in Lines 17, 22, and 28 of this Worksheet will be hauled to the landfill
in a 44,000-lb. truck.  The landfill is assumed to be 100 miles away; the
hourly cost of truck and driver is $60 and the average trip speed is
40 mph.  Adequate dividers will be supplied so that mixed loads can be
carried.
     34.  Number of trips required:  If it is assumed that a cu. yd. of
earth weighs approximately 2000 Ibs., the hauling of these waste residues
will require seven trips.
     35.  Costs of hauling decontamination residues (Line 33 x Line 34):
At $300 per round trip, total hauling costs would be $2100.
     36.  Flush pumps and transfer lines:  All pumps and piping used to
transfer hazardous waste are flushed to remove contaminants.  This
process is assumed to cost $2000.
     37.  Decontaminate equipment:  All materials handling equipment
used on-site must be decontaminated.  This is assumed to cost $500.
     3d.  Decontaminate containers:  In the example, it is assumed that
all drums kept on-site will be crushed and buried in a landfill, at a
total cost of $1000.
     39.  Total costs of decontaminating facility (sum of Lines 4, 8,
11, 16, 19, 24, 26, 30, 32, 35-38):  Total costs of decontaminating the
facility, based on the above assumptions, are estimated to be $14,070.

D.   Professional Certification

     1.   Number of person-hours required for inspections:  It is assumed
that 16 hours are required for periodically inspecting all aspects of
closing the tanks and impoundments.      ,
     2.   Cost per person-hour:  In this case, assume that a registered
independent professional engineer may be hired at a cost of $75 per hour.
     3.   Total costs of independent professional engineer's time  (Line 1
x Line  2):  This yields a total cost of $1200 for the independent pro-
fessional engineer.
                                  9-100

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     4.   Number of technical hours required for administrative duties:
Assume that 8 hours are required from the owner's or operator's staff for
administrative duties connected with employing an independent professional
engineer.
     5.   Person-hour costs for technical administrative duties:  It is
assumed that the total fully-loaded costs for the owner's or operator's
staff are $30 per hour.
     6.   Total administrative costs for technical labor (Line 4 x Line 5):
Given the above assumptions, the total administrative costs for technical
labor are $240.
     7.   Number of clerical hours required for administrative duties:
Assume that 5 hours of clerical time are required for the necessary
typing and certifications.
     8.   Person-hour costs for clerical administrative duties:  Fully-
loaded costs of clerical time are assumed to be $8 per hour.
     9.   Total administrative costs for clerical labor (Line 7 x Line 8):
Given the above assumptions, total clerical costs are $40.
    10.   Total administrative costs (Line 6 + Line 9):  Summing technical
and clerical labor, the administrative costs are $280.
    11.   Total certification costs (Line 3 + Line 10):  The total costs
for certification, including engineer's fees and administrative costs, are
$1480.

E.   Total Costs Including Administration and Contingencies

     Items 1 through 3 give the costs of all activities on each of the
preceding worksheets.  Line 4 is the total of Lines 1 through 3, $85,815.
     5.   Contingencies:  A general provision for contingencies of 15
percent of Line 4 has been included.
     6.   Administrative and supervisory cost:  For administrative tasks,
including taxes, insurance, and administration and supervision not included
elsewhere, a total of 15 percent of total costs from Line 4 is used.
     7.   Total costs of closure (Line 4 + Line 5 -t- Line 6):  The
total costs for closing the tanks and impoundments are estimated for
the sample case to be $111,559.

                                  9-101

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                         MULTIPLE PROCESS FACILITY
               WORKSHEET A - CHARACTERIZING THE WASTE (#1)
1.   Description of the waste
         Organic solvent
2.   Chemical composition
         (Not given)
3.   Physical state of the waste
         Liquid
4.   Heat of combustion of the waste
         18,000 BTU/lb.(135,000 BTU/gal.)
5.   Specific gravity of the waste
         .9
6.   Maximum inventory of the waste
         60,000 gallons bulk storage
          5,500 gallons in drums
7.   ID numbers for areas holding these wastes
         Tanks T-l to T-4
                                      9-102

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                    MULTIPLE PROCESS FACILITY
          WORKSHEET A - CHARACTERIZING THE WASTE  (#2)
Description of the waste
    Slop oil
Chemical composition
    (Not given)
Physical state of the waste
    Liquid
Heat of combustion of the waste
    16,000 BTU/lb.(126,720 BTU/gal.)
Specific gravity of the waste
    .95
Maximum inventory of the waste
    10,000 gallons bulk storage
ID numbers for areas holding these wastes
    Tank T-5
                              9-103

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                       MULTIPLE PROCESS FACILITY
               WORKSHEET A - CHARACTERIZING THE WASTE (#3)
1.   Description of the waste
         Oily wastes
2.   Chemical composition
         (Not given)
3.   Physical state of the waste
         Mixture (95% liquids, 5% sludge)
4.   Heat of combustion of the waste
         (Not given)
5.   Specific gravity of the waste
         (Not given)
     Maximum inventory of the waste
         30,000 gallons in holding basin
          5,500 gallons in drums
7.   ID numbers for areas holding these wastes
         Impoundment S-l
                                    9-104

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                       MULTIPLE PROCESS FACILITY
                WORKSHEET A - CHARACTERIZING THE WASTE (#4)
1.   Description of the waste
         Pickling liquor waste
2.   Chemical composition
                              •
         (Not-given)
3.   Physical state of the waste
         Liquid
4.   Heat of combustion of the waste
         0
5.   Specific gravity of the waste
         1.05
6.   Maximum inventory of the waste
         30,000 gallons in holding basin
7.   ID numbers for areas holding these wastes
         Impoundment B-l
                                     9-105

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                       MULTIPLE PROCESS FACILITY
               WORKSHEET A - CHARACTERIZING THE WASTE (#5)
1.   Description of the waste
         Solidified pickling liquor wastes
2.   Chemical composition
         (Not given)                        *
3.   Physical state of the waste
         Solid
4.   Heat of combustion of the waste
         (Not given)
5.   Specific gravity of the waste
         2.2
6.   Maximum inventory of the waste
         8,000 cu. ft. in storage pile
7.   ID numbers for areas holding these wastes
         None
                                     9-106

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                        MULTIPLE PROCESS FACILITY
                   WORKSHEET B - TREATING THE INVENTORY
      Waste inventory at time of closure
          Waste solvents
          Slop oil
          Oily wastes
          Pickling liquor wastes
          Solidifed pickling wastes
      Methods of treatment or removal
          Waste solvents
          Slop oil
          Oily wastes
          Pickling liquor wastes
          Solidified pickling wastes
 Disposing of Oily Waste
 3.   Composition of waste
          80% solvent, 15% slop oil, 5% sludge
 4.   Amount of waste produced
          28,400 gal. solvent, 5,325 gal. slop oil,
 5.   Amount of sorbent used in sludge treatment
 6.   Cost of sorbent used
      a.  Cost of materials
 7.   Amount of residue generated
 8.   Unit cost of disposing or removing residue
 9.   Total cost of disposing or removing residue
         (Line 7 x Line 8)
10.   Costs of hauling residue
11.   Number of trips required
12.   Total cost of hauling residue (Line 7  x Line 10)
13.   Costs of disposing or removing oily waste
         (Line 6 + Line 9 + Line 11)
65,500 gal.
10,000 gal.
35,500 gal.
30,000 gal.
 8,000 cu. ft.

Reuse as boiler fuel
Incinerate
Separate; recover solvents,
incinerate slop oils, landfill
sludges
Solidify, landfill
Landfill
               1,775 gal. sludge
               1:1 ratio with oils
               0
               0
               22 tons
               $50/ton
               $1100

               $300/trip
               1
               $300
               $1400
                                   9-107

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WORKSHEET B (continued)
Treating or Removing Pickling Liquor Waste
14.
15.
16.
17.
18.
19.
20.
21.
22.
23.
24.
25.
26.
Amount of cement required for solidification
Total amount of cement required
Cost of cement
Cost of materials (Line 15 x Line 16)
Amount of residues produced by treating inventory
Amount of other residues already on-site
Total amount of pickling residues
(Line 18 + Line 19)
Unit cost of disposing or removing residue
Total cost of disposing or removing residue
(Line 20 x Line 21)
Costs of hauling residues
Number of trips required
Total costs of hauling (Line 23 x Line 24)
Costs of disposing or removing pickling liquor
waste (Line 17 + Line 22 + Line 25)
1 sack/ 10 gal
3000 sacks
$2.50/sack
$7,500
272.4 tons
540 tons
812.4 tons
$50/ton
$40,620
$300/trip
37
$11,100
$59,220
Removing Waste Solvent
27.

Amount of waste solvent
a. Amount of solvent in inventory
b. Amount of solvent obtained from oily
93,900 gal.
65,500 gal.
28,400 gal.
            waste inventory treatment
28.  Method of removal

29.  Cost of removal
Treating Slop Oil
30.  Amount of slop oil on-site
     a.  Amount in inventory
     b.  Amount generated from disposing or
            treating oil waste inventory
31.  Method of treatment
32.  Unit cost of treatment:
33.  Total cost of treatment  (Line 30 x Line 32)
34.  Unit costs of hauling residues
Recovery and reuse
as boiler fuel
15,325 gal.
10,000 gal.
5,325 gal.

Incinerate
$0.60/gal.
$9,195
$150/trip
                                  9-108

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WORKSHEET B (continued)


35.  Number of trips required

36.  Total costs of hauling (Line 34 x Line 35)

37.  Costs of treating slop oil

38.  Total costs of treating inventory
        (Sum of Lines 6, 9, 12, 17, 22, 25, 29,
         33 and 36)
                                   9-109

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                        MULTIPLE PROCESS FACILITY
                WORKSHEET C - DECONTAMINATING THE FACILITY
 Tank Cleaning
 1.   Cleaning method used
 2.   Capacity to be cleaned
 3.   Unit cleaning costs
 4.   Total costs of steam cleaning
      (Line 2 x Line 3)
 5.   Quantity and type of residues generated

 6.   Method of disposal
 7.   Cost of disposal
 8.   Total cost of disposal
      (Line 5 x Line 7)
 9.   Cost of hauling residues
10.   Number of trips required
11.   Total costs of hauling (Line 9 x Line 10)
12.  . Total costs of tank cleaning
Decontaminating the Impoundment
13.
14.
15.   Unit costs of sandblasting
16.   Total costs of sandblasting
      (Line 14 x Line 15)
      Quantity of residues generated
      Unit costs of disposing of residue
      Cleaning method used - Surface Impound-
                  ,  "   ,      ment 1
      Area to be cleaned
17.
18,
19,
      Total costs of disposing of residue
      (Line 17 x Line 18)
20.   Cleaning method used - Surface Impound-
                             ment 2
21.   Area to be cleaned
22.   Amount of clay removed
23.   Unit cost of removing clay
24.   Total cost of removing clay
      (Line 22 x Line 23)
Steam cleaning
70,000 gallons
$.02/gallon

$1,400
8,750 gallons of contaminated
washwaters
Surface impoundment
$.05/gallon

$438
$600/trip
2
$1200
$3038

Sandblasting
1560 sq. ft.
$.60/sq. ft.

$936
2 tons of contaminated sand
$50/ton
$100

Clay removal and landfill
  disposal
1560 sq. ft.
57.8 cu. yds.
$1.60/cu. yd,
$92
                                   9-110

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WORKSHEET C (continued)
25.  Unit cost of disposing of residue (clay)
26.  Total costs of disposal
     (Line 22 x Line 25)
Soil Removal and Miscellaneous Site Cleanup
27.  Soil area contaminated

28.  Amount of soil removed
29.  Unit cost of removing soil
30.  Total cost of removing soil
     (Line 28 x Line 29)
31.  Unit costs of contaminated soil
     disposal
32.  Total costs of disposing of soil
     (Line 28 x Line 31)
33.  Hauling costs for decontamination
     wastes (including impoundment cleanup)
34.  Number of trips required
35.  Total costs of hauling
36.  Costs of flushing pump and transfer
                                             #
     lines
37.  Decontaminate equipment
38.  Decontaminate containers
39.  Total costs of decontaminating the
     facility
$30/cu. yd.
$1734
2.5% of site area
(242 sq. yd.)
80.7 cu. yd.
$1.60/cu. yd.
$129

$30/cu. yd.

$2421

$300/trip

7
$2100
$2000

$500
$1000
$14,070
                                  9-111

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                        MULTIPLE PROCESS FACILITY
                 WORKSHEET D - PROFESSIONAL CERTIFICATION
 1.   Number of person hours required for inspections     16 hours
 2.   Cost per person-hour: engineer                      $75
 3.   Total costs of independent professional engineer's  $1200
      time (Line 1 x Line 2)
 4.   Number of technical hours required for              8 hours
      administration
 5.   Cost per person-hour: technical                     $30
 6.   Total administrative costs for technical            $240
      labor (Line 4 x Line 5)
 7.   Number of clerical hours required for               5 hours
      administration
 8.   Costs per person-hour: clerical                     $8
 9.   Total administrative; costs for clerical labor       $40
      (Line 7 x Line 8)
10.   Total administrative costs (Line 6 + Line 9)
11.   Total certification costs (Line 3 + Line 10)
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                      MULTIPLE  PROCESS  FACILITY
                  WORKSHEET E - TOTAL COSTS INCLUDING
                   ADMINISTRATION AND CONTINGENCIES
1.   Costs of disposing of inventory                       $ 70,265
     (From Worksheet B)
2.   Costs of decontaminating the facility (From           $ 14,070
     Worksheet C)
3.   Costs of professional certification (From             $  1,480
     Worksheet D)
4.   Subtotal                                              $ 85,815
5.   Contingencies                                         $ 12,872
6.   Administration                                        $ 12,872
7.   Total closure costs                                   $111,559
     (Line 4 + Line 5 + Line 6)
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9.7               EXAMPLE - POST-CLOSURE COST ESTIMATES

     A large flat landfill of 200 acres has been closed in accordance
with the EPA interim status regulations.  This landfill consists
of rather closely spaced narrow trenches that are protected by clay
covers and cover vegetation.  The facility soil is a soil which is
mostly clay in content.  All of the facility is planted with grass to
resist erosion.
     The post-closure operations at this facility have been planned to
carry out the requirements of the interim status regulations.  The ac-
tivities planned are as follows:
     •  periodically inspecting the facility
     •  mowing
     •  routine erosion repairs
     •  replacing security fences (as needed)
     •  fertilizing
     •  leachate pumping and disposal
     •  ground-water monitoring
     •  monitoring well replacement (as needed)
     •  repair of severe erosion caused by storms
     •  post-closure administrative services
These activities are costed in the attached annotated worksheets.  All of
these activities are costed based on the assumption that the facility is
completely closed and that no "free" assistance is available from an
active portion of the facility.  This means that some of the supporting
facilities such as office space that are available during closure are
not automatically available during the post-closure period.
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              SAMPLE POST-CLOSURE COST ESTIMATING WORKSHEETS

A.   Periodically Inspecting the Facility
     1.  Number of technical management person-hours required for each
inspection:  Each inspection at this closed hazardous waste facility
will be conducted by two people in a rented vehicle.  We are of the
opinion that two people are needed to conduct the inspection of the
large closed waste disposal area (200 acres) and that an extra measure
of safety is afforded by having two inspectors.  Each inspection takes
a full day of work by two technically trained managers.
     2.  Annual number of routine inspections:  Six routine inspections
will be conducted during each year of the post-closure period.  These
will be conducted on a bimonthly basis.
     3.  Person-hour costs for technical management labor:  The fully-
loaded labor rate for this technically trained labor is $30 per hour.
     4.  Technical labor costs for annual routine inspections (Line 1 x
Line 2 x Line 3):  The technical labor cost for these annual routine
inspections is the product of the person-hours required for each inspec-
tion, the number of inspections planned, and the technical labor rate.
     5.  Annual number of engineer-supported inspections:  In addition
to the routine inspections described above, two annual engineer-supported
inspections are planned.  These inspections use a team of professional
engineers and one of our technical managers.  The engineer is a state-
certified professional engineer from an independent firm that is contracted
to supply professional services to the hazardous waste disposal facility.
     6.  Number of independent state-certified engineering hours for each
engineer-supported inspection:  For each inspection, eight hours of the
engineer's time is required.
     7.  Number of technical management hours for each engineer-supported
inspection:  For each inspection, eight hours of technical labor is
required.  This requirement is in addition to the engineering labor that
is required.
     8.  Person-hour cost for a professional engineer:  The quoted cost
of engineering services is $75 per hour.  These services will be obtained
from an independent engineering firm.

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      9. Engineering labor costs for the engineer-supported inspections
(Line 5 x Line 6 x Line 8):  The cost of the engineering labor is  the
product of the number of engineer-supported inspections, the number of
engineering hours needed for each inspection, and the person-hour  cost
of engineering services.
     10. Technical labor costs for the engineer-supported inspections
(Line 3 x Line 5 x Line 7):  The technical managerial labor costs  for
the engineer-supported inspections is the product of the labor rate for
technical labor, the number of inspections required, and the technical
labor hours required for each inspection.
     11. Labor costs for the engineer-supported inspections (Line  9 +
Line 10):  The total labor costs for the engineer-supported inspections
is the sum of the engineering labor and technical labor costs.
     12. Cost of renting the truck for each inspection:  A rented  pick-
up truck is used for transporting the inspectors throughout the hazardous
waste disposal facility.  The quoted rate for the truck is $25 per day and
$.14 per mile.  In addition, the renter must supply gasoline.  The mileage
for each inspection is 50 miles including the trips between the facility
and the rental agency.  This results in a total cost for the truck of
$36 per day ($25 rental, $7 mileage, and $4 gasoline).  The gasoline
value is estimated based on a truck mileage of 15 mpg and a gasoline
price of $1.20 per gallon.
     13. Annual cost of renting the truck for inspections (Line 2  -f Line
5 x Line 12):  The total annual truck rental cost is the product of the
total number of inspections needed (both routine and engineer-supported)
and the daily truck rental cost.
     14. Total annual inspection cost (Line 4 + Line 11 + Line 13):  The
total cost of conducting this post-closure inspection program is the sum
of the annual total labor costs for the routine inspections, the annual
labor costs for the engineer-supported inspections, and the annual rental
costs for the truck.
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B.   Routine Monitoring and Maintenance Activities
Mowing Operations
     1.  Facility acreage:  The waste disposal area of  this hazardous
waste facility is 200 acres.  This area includes the cover of the waste
disposal trenches and land close to the trenches.
     2.  Mowing labor:  The waste disposal area is to be mowed periodically
to promote the growth of cover vegetation and to inhibit the growth of
large deep-rooted vegetation such as young trees.  This mowing is to be
carried out on a contract basis by a mowing service.  The quoted labor
rate for this service is $14.28 per acre mowed.
     3.  Mowing equipment:  The quoted rate for the mowing equipment is
$5.37 per acre mowed.  This rate includes fuel and all  equipment costs.
     4.  Unit mowing cost (Line 2 + Line 3):  Adding the labor rate and
the equipment rate yields the total contracted mowing rate (unit cost) for
each acre mowed.  Cheaper agricultural methods cannot be used because of
the impact of the heavier equipment on the cover.
     5.  Annual frequency of mowing:  Mowing of the waste disposal area
is required once a year during the post-closure period.  This frequency
of mowing will encourage the growth of cover vegetation and will suppress
the growth of trees and other deep-rooted vegetation.
     6.  Annual cost of mowing (Line 1 x Line 4 x Line  5):  The annual
cost of mowing is the product of the facility acreage,  the unit mowing
cost, and the annual frequency of mowing.

Routine Erosion Damage Repair
     7.  Annual routine erosion rate:  The annual routine loss of soil
from the facility is computed using the Universal Soil Loss Equation
(USLE).
             A = RKLSCP
         A » Average soil loss, tons/acre
         R = Rainfall and run-off erosivity index
         K * Soil erodibility factor
         L • Slope - length factor
         S » Slope - steepness factor
         C = Cover/management factor (type of vegetative cover)
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         P = Practice factor (terracing, contour plowing)
This equation computed for the sample facility's location yields an
annual soil loss of 0.12 tons per acre.  With a soil density of approxi-
mately 100 Ibs. per cu. ft., 0.089 cu. yds. are lost from each acre.  In
our subsequent computations, we make the very conservative assumption
that all of the lost soil will have to be replaced and reseeded.
     8.  Total annual routine erosive loss (Line 1 x Line 7):  The total
annual routine soil loss is the product of the acreage times the annual
soil loss per acre.
     9.  Unit cost for land excavation of soil:  Replacement soil will be
obtained on-site at the facility.  Since the amount of soil required is
very small compared to the daily capacity of earth-moving machinery,
hand labor will be used to excavate the soil.  The rate stated here is
a fully-loaded rate for union labor working for an independent contractor.
This unit cost is based on contractor quotes.
    10.  Unit cost for on-site transportation of soil:  The excavated
soil is transported by truck on-site to the location where the erosion
repair is to be made.  This service will be provided by an independent
contractor.
    11.  Unit cost for compacting the soil by hand:  The unit cost of
hand compacting the new soil as a repair for erosion damage is estimated
to be the same as for hand excavation of the soil.  This service will
be provided by an independent contractor.
    12.  Unit cost of seeding:  The cost of seeding is a function of
the surface area of the new bare soil.  In our estimates, we assume
that a small gully (or gullies) have formed.  The ratio of surface area
to soil volume is small.  This new soil is seeded with the same type of
grass as is used for the original cover vegetation.
    13.  Aggregate unit cost of repairing routine soil erosion damage
(Line 9 + Line 10 + Line 11 + Line 12):  The aggregate unit cost of
repairing the routine soil erosion is the sum of the excavation unit
cost, the on-site trucking, the hand compacting of the soil, and hand
seeding of the bare soil.
    14.  Total annual cost for repairing erosive damage of a routine
nature (Line 8 x Line 13):  The total annual cost of such routine erosive

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repairs under average rainfall conditions is the product of the amount
of soil lost and the unit aggregate cost for erosion damage repairs.
     15. Adjustment factor to account for unusually wet seasons:  The
above cost (Line 14) is computed for average rainfall conditions at the
facility location.  A safety factor of 2 is applied which is the equiva-
lent of increasing the rainfall and runoff erosivity index (within the
Universal Soil Loss Equation) from 150 to 300.  This changes the facility's
rainfall from its actual mid-Atlantic level to the high southern levels.
This conservative assumption is required to allow for the annual variation
in routine rainfall-caused erosion.
     16. Adjusted annual cost for repairing routine erosion damage (Line
14 x Line 15):   The adjusted annual cost for erosion repair of a routine
nature is the product of the average annual cost and the adjustment fac-
tor.

Replacing the Fence
     17. Frequency of replacing the fence:  Security at the facility is
provided by a 6-ft. high chain link fence that has been established along
the entire perimeter of the facility (11,808 ft. in length).  This fence
is made of galvanized #9 wire.  Operating experience- at this hazardous
waste facility indicates that the fence must be replaced every 15 years.
Thus, during the anticipated 30-year duration of the closure period, the
fence will have to be replaced once.
     18. Facility perimeter:  The length of the security fence is the
length of the facility oerimeter (11,808 ft.).
     19. Unit cost of replacing the fence:  Quotes were obtained from
fencing suppliers for a new fence of equal specifications.  The value
given here is a unit cost per linear foot for an installed fence.
     20. Total cost of fence replacement (Line 18 x Line 19):  The cost
of replacing the perimeter security fence is the product of the perimeter
footage and the unit cost of the installed fencing.
     21. Pro-rated annual cost of fence replacement:  The total cost of
replacing the security fence is pro-rated to each year by dividing the
total cost (Line 20) by the number of years in the post-closure period
(30 years).

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Fertilizing
     22. Unit cost of fertilizing:  The hazardous waste disposal facility
has relatively poor soil resulting in the experienced necessity of annual
fertilizer applications until the vegetation has become established, & periodic
applications .thereafter. --Type 10/6/4 fertilizer costing $0.12 per Ib. (in
50-lb. bags) is applied at a rate of 500 Ibs. per acre.  This corresponds
to a nitrogen application rate of 50 Ibs. per acre.  The unit cost of ferti-
lization is the- sume of the labor, materials and equipment costs.
         Labor                      $69.10/acre
         Materials                  $60.00/acre
         Equipment                  $ 5.00/acre
Previous experience at this facility has shown that this application
rate for fertilizer is satisfactory to maintain the vegetation.
     23.  Number of applications of fertilizer for the first 3 years:  One
application of fertilizer is needed each year for a total of 3 applications.
     24.  Number of applications of fertilizer for remaining -years of post-
closure (Years 4 through 30):  One application of fertilizer is needed every
5 years, or a total of 5 applications for the remainder of post-closure.
     25.  Total costs of fertilizing for the first 3 years of post-
closure (Line 1 x Line 22 x Line 23):  The cost of fertilizing for the
first 3 years is the product of the acreage fertilized, the unit cost of
fertilization and the frequency of application during the first 3 years.
The costs of fertilizing for the first 3 years are then $80,460.
     26. Total costs of fertilization for years 4 through 30 of post-
closure (Line 1 x Line 22 x Line 24):  The cost of fertilizing is the
product of the acreage fertilized, the unit cost of fertilizing, and
the frequency of application during the years 4 through 30.  The costs
for fertilizing for the remainder of post-closure is then $134,100.
     27. Total costs of fertilizing during post-closure (Line 25 + Line
26) :  The total fertilization costs are the sum of the costs for ferti-
lizing during the first 3 years and the 5 applications required during
the remainder of post-closure.  The total costs for fertilizing for
the entire 30-year period are then $214,560.
     28. Total annual costs of fertilizing (Line 27 -f 30):  The
total costs  for fertilizing for the 30-year period is divided by the

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30 years of the post-closure period to yield an annual cost of $7152.

Ground-Water Monitoring Well Replacement
     29. Unit cost for well replacement:  The lowest observed depth of
the water table has been closer to the surface than 50 ft. throughout the
active operation of the facility.  A replacement well to a depth of
aprpoximately 50 ft. will cost $425 when installed by an independent
contractor ($8.50 per vertical linear ft.).  This quoted price includes
a suitable casing.
     30. Number of wells needing replacement:  The monitoring wells have
a relatively long useful lifetime as do residential wells.  It is antici-
pated that two wells will have to be replaced during the post-closure
period.
     31. Total cost of monitoring well replacement (Line 29 x Line 30):
The total post-closure period cost of well replacement is the unit cost
of each well multiplied by the number of wells required in the post-
closure period.

Leachate Pumping and Disposal
     32. Frequency of removing the leachate:  Leachate is removed perio-
dically from the hazardous waste facility risers by means of a vacuum truck.
Every month, the truck circulates to each riser pumping out the collected
leachate.  This service is performed by an independent contractor.
     33. Average total monthly leachate withdrawal:  Since the facility's
cover system is quite effective in reducing infiltration, only 2000 gals.
of leachate (average value) will have to be removed each month.  This
leachate is removed to an off-site disposal area.
     34. Unit cost of removing the leachate to an active off-site disposal
area:  The unit cost of removing the leachate includes driving the vacuum
truck to each riser at the facility and removing the leachate and deliver-
ing the truckload of leachate to the off-site disposal area.  A relatively
high per-gallon removal cost is quoted because of the necessity of collec-
ting a small amount of leachate from each of the widely dispersed risers
throughout the large facility.  This cost includes, transportation to the
TSDF.
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     35. Total annual cost of removing the leachate (Line 32 x Line 33 x
Line 34 x 12):  The annual leachate removal cost is the product of the
monthly leachate volume removed, the number of months in a year, and the
unit cost per gallon removed.
     36. Unit cost for removing leachates to an off-site TSDF:  The unit
cost for off-site disposal of the leachate material is $.05/gal.  This
material is disposed of in a surface impoundment.
     37. Annual costs for off-site disposal (Line  32 x Line 33 x Line 36
x 12):  The cost of disposing of the material in the off-site surface
impoundment is the product of the amount of leachate disposed and the
unit cost for the disposal.
     38. Total annual cost for removing and disposing of leachates (Line
35 + Line 37):  The total cost for leachate removal and disposal is the
sum of the removal cost and the disposal cost.

Ground-Water Monitoring

     39. Number of wells monitored:  This hazardous waste facility has
12 ground-water monitoring wells.  One well is upgradient and 11 wells
are downgradient from the disposal area.
     40. Number of samples taken per well (annual):  Two "cycles" of
ground-water sampling will be conducted annually.   One ground-water
quality analysis and two ground-water contamination analyses are to be
carried out.  One sample may be used for both the  ground-water quality
and ground-water contamination analyses.  Therefore, two samples are
taken from each well annually.
     41. Total number of samples (annual) (Line 39 x Line 40):  The total
number of ground-water samples taken annually is the product of the
number of monitoring wells and the number of samples taken annually from
each well.
     42. Number of hours for collecting the sample (per sample):  Each
sample requires two hours of collection time.  The well must be pumped
dry and allowed to refill.  Then a sample is taken.  The facility ex-
perience is that approximately two hours are required for each well
sampling (including' some time for moving about the fields).
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     43.  Total number of hours for collecting the sample (Line 41 x
Line 42):  Annually, 24 samples will have to be collected, requiring
48 hours of labor.
     44.  Total number of hours for preparing and delivering the sample:
The total number of hours required for packaging and delivering the
samples is six hours per year.
     45.  Total sample handling hours (Line 43 + Line 44):  The annual
total time for collecting and delivering the ground-water samples is
54 hours.
     46.  Person-hour costs for handling ground-water samples:  The
person-hour costs for handling the samples is based on the facility ex-
perience of $15 per hour fully-loaded.
     47.  Total sample handling costs (Line 45 x Line 46):  The total
labor cost for handling the samples is the product of the hours required
and the unit labor costs.
     48.  Unit cost of ground-water quality analysis:  The unit cost
of an analysis for the following parameters is $77 per analysis:
          Chloride                  $ 6/sample
          Iron                      $12/sample
          Manganese                 $12/sample
          Phenols                   $25/sample
          Sodium                    $12/sample
          Sulfate                   $10/sample
     49.  Unit cost of ground-water contamination analysis:   The unit
cost of an analysis for the following parameters is $108 per analysis:
          pH                        $ 4/sample
          Specific Conductance      $ 4/sample
          Total Organic Carbon      $25/sample
          Total Organic Halogen     $75/sample
     50.  Total cost of ground-water quality analysis (annual)  (Line 39
x Line 48):   The annual cost for analysis of water quality is the product
of the number of wells and the unit cost of the analysis.
     51.  Total cost for ground-water contamination analysis (annual)
(Line 41 x Line 49):  The annual cost for analysis for ground-water
contamination is the product of the number of sample sets to be analyzed
and the unit cost of the analysis.
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     52.  Total annual ground-water monitoring costs (Line 49 +• Line 50 +
Line 51):  The total annual cost for ground-water analysis is the sum of
the ground-water quality analysis cost, the ground-water contamination
analysis cost, and the sample handling cost.

Routine Maintenance Summation

     53-60.  The annual cost for each of the routine maintenance and
monitoring operations are added together to yield the total cost (annual).
This cost does not include administrative costs which .are computed on a
separate worksheet (Line 53 + Line 54 + Line 55 + Line 56 + Line 57 +
Line 58 + Line 59).
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C.   Erosion Damage Contingency Scenario
     1.  Percentage of vegetation removed:  Some unplanned events that
will create additional demands for care will occur during the duration of
the post-closure period.  This worksheet computes the additional cost
that would result from such an unplanned event that removes 30% of the
vegetative cover from the hazardous waste facility.  After the vegetation
is removed, the soil remains bare for one month exposed to normal rainfall.
Resulting erosive damage is repaired and the bare acreage is revegetated.
The one month lapse between the damaging event and the revegetation allows
for delays in the discovery of the damage and the time required for the
revegetation steps.
     2.  Facility acreage:  The entire facility is impacted by the event.
     3.  Acreage reduced to bare soil (Line 1 x Line 2):  The acreage
stripped of vegetation is the product of the percentage of vegetation
removed and the total acreage of the facility.
     4.  Annual per acre soil loss rate (without vegetative cover) :  The
annual soil loss for each acre of bare soil is computed using the Univer-
sal Soil Loss Equation (USLE).
             A = RKSLCP
         A = Average soil loss, tons/acre
         R » Rainfall and run-off erosivity index
         K » Soil erodibility factor
         L = Slope - length factor
         S » Slope - steepness factor
         C = Cover/management factor (type of vegetative cover)
         P « Practice factor (terracing, contour plowing)
This equation is for erosion resulting from rainfall subsequent to the
event that removed the vegetation.
     5.  Monthly bare ground soil loss rate:  The annual loss rate
computed in Line 4 is converted to a one month loss rate.  This conver-
sion is accomplished by dividing the annual loss rate by 12.
     6.  Amount of soil lost before repairs are instituted:  The amount
of soil lost from the bared ground is the product of the monthly loss
rate per acre and the acreage of the facility that is exposed.  This
product is then multiplied by two to allow for soil lost during the
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removal of the vegetation.  The ground is assumed to be bare for about
one month before the repairs and replanting are completed.  The conversion
to volume of soil lost is carried out assuming a soil density of 100 Ibs.
per cu. ft.
     7.  Unit cost for excavating and loading soil:   The unit cost for
excavating and loading replacement soil is computed using a 2 cu. yd.
front end loader.  This operation will be performed under contract.
     8.  On-site haul of excavated soil to the area needing repair:  The
excavated soil is transported on-site over a 2000 ft.  distance by trucks
operating under contract.
     9.  Filling and compacting eroded areas of the facility:  The replace-
ment soil is filled and compacted into the eroded areas using a dozer
operating under contract.
    10.  Total unit cost for replacing soil (Line 7 + Line 8 + Line 9):
The total unit cost of replacing soil is the sum of the excavation-
loading, hauling and filling unit costs.  These unit costs were obtained
from estimates made by a local contractor.
    11.  Cost of replacing the lost soil (Line 6 x Line 10):  The total
cast for replacing the lost soil is the product of the amount of soil
lost times the unit cost for soil replacement.
    12.  Unit cost for seeding the bare soil:  The unit cost for seeding
the bare acreage is computed from the sum of the labor, materials and
equipment costs.
             Labor                  $69.10/acre
             Materials              $13.90/acre
             Equipment              $ 5.00/acre
The grass planted is Kentucky bluegrass available from a local supplier
at $0.32 per Ib. in 50-lb. bags.  The application rate for this seed is
1 Ib. per 1000 sq. ft. (or 43.56 Ibs. per acre).  This is less than one-
third of the seed application rate used for home lawns.  Experience has
shown this seeding rate to be satisfactory.
    13.  Unit cost for fertilizing:  Since the soil at this hazardous
waste facility is quite poor, fertilization is necessary.  Type 10/6/4
fertilizer costing $0.12 per Ib. (in 50-lb. bags) is applied at a rate
of 500 Ibs. per acre.  This corresponds to a nitrogen application rate

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of 50-lbs. per acre.  The unit cost of fertilization is the sum of the
labor, materials and equipment costs.
         Labor                      $69.10/acre
         Materials                  $60.00/acre
         Equipment                  $ 5.00/acre
Previous experience at this facility has shown that this application
rate for fertilizer is satisfactory.
     14. Unit cost for mulching with straw:  Since the soil is bare, pro-
tection from erosion must be provided while the grass starts to grow.
This is achieved by using straw mulch at an application rate of 1 ton
per acre.  The unit cost of mulching is the sum of the labor, materials
and equipment costs.
         Labor                      $34.50/acre
         Materials                  $85.00/acre
         Equipment                  $ 5.00/acre
     15. Total unit replanting cost (Line 12 + Line 13 + Line 14):  The
total unit replanting cost is the sum of the seeding, fertilizing, and
mulching costs.  Lime is not applied at this facility because it is not
recommended by the Agricultural Extension Service (USDA).
     16. Total replanting costs (Line 3 x Line 15):  The total replanting
cost for the facility is the product of the acreage to be replanted and
the unit cost of replanting each acre.
     17. Number of erosive incidents expected in the post-closure period:
It is anticipated that such highly erosive incidents will occur twice
during the post-closure period.  These will be either major storms or
floods.
     18. Total cost for repairing damage from erosive incidents (Line 11
+ Line 16 x Line 17):  The total post-closure cost for repairing the damage
from such incidents is the sum of the repair costs for each incident
(soil and vegetation) multiplied by the number of incidents expected in
the 30-year post-closure period.
     19. Total annual cost for repairs required by erosive incidents
(Line 18 4- 30 years) :  The total cost of repairing the damage from the
two incidents is divided by the 30 years of the post-closure period to
yield the annual cost for contingency repairs.

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D.   Initial Replanting to Establish Vegetation
     1.  Percentage failures of vegetation per year:  It is estimated
that in this climate, 10 percent of the vegetation will fail per year due
to inadequate initial establishment.
     2.  Number of years required for full vegetation:  It is estimated
that three years will be necessary for full establishment of vegetation
to the point replanting will no longer be necessary.
     3.  Facility acreage:  Facility acreage is 200 acres.
     4.  Total acres to be replanted due to initial failure of vegetation
(Line 1 x Line 2 x Line 3):  Total acres to be replanted are then 60
acres.
     5.  Annual per acre soil loss:  The annual soil loss for each acre
of bare soil is computed using the Universal Soil Loss Equation (USLE).
             A = RKLSCP
         A * Average soil loss, tons/acre
         R = Rainfall and run-off erosivity index
         K « Soil credibility factor
         L = Slope - length factor
         S a Slope - steepness factor
         C » Cover/management factor (type of vegetative cover)
         P » Practice factor (terracing, contour plowing)
This equation is for erosion resulting from rainfall subsequent to the
event that removed the vegetation.
     6.  Monthly bare ground soil loss rate:  The annual loss rate com-
puted in Step 4 is converted to a one-month loss rate.  This conversion
is accomplished by dividing the annual loss rate by 12.
     7.  Amount of soil lost before repairs are instituted (Line 4 x
Line 6) :  The amount of soil lost from the bared ground is the product
of the monthly loss rate per acre and the acreage of the facility that
is exposed.  This product is then multiplied by two to allow for soil
lost during the removal of the vegetation.  The ground is assumed to be
bare for about one month before the repairs and replanting are completed.
The conversion to volume of soil lost is carried out assuming a soil
density of 100 Ibs. per cu. ft.
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     8.  Unit cost for excavating and loading soil:  The unit cost for
excavating and loading replacement soil is computed using a 2 cu. yd.
front end loader.  This operation will be performed under contract.
     9.  On-site haul of excavated soil to area needing repair:  The
excavated soil is transported on-site over a 2000 ft. distance by trucks
operating under contract.
    10.  Filling and compacting eroded areas of the facility:  The replace-
ment soil is filled and compacted into the eroded areas using a dozer
operating under contract.
    11.  Total unit cost for soil replacement (Line 8 + Line 9 + Line 10):
The total unit cost of soil replacement is the sum of the excavation-
loading, hauling and filling unit costs.  These unit costs were obtained
from estimates made by a local contractor.
    12.  Cost of soil replacement (Line 7 x Line 11):  The total cost for
replacing the lost soil is the product of the amount of soil lost times
the unit cost, for soil replacement.
    13.  Unit cost for seeding bare soil:  The unit cost for seeding the
bare acreage is computed from the sum of the labor, materials and equip-
ment cos ts.
             Labor                  $69.10/acre
             Materials              $13.90/acre
             Equipment              $ 5.00/acre
The grass planted is Kentucky bluegrass available from a local supplier
at $0.32 per Ib. in 50-lb. bags.  The application rate for this seed is
1 Ib. per 1000 sq. ft. (or about 40 Ibs. per acre).  This is less than one-
third of the seed application rate used for home lawns.  Experience has
shown this seeding rate to be satisfactory.
    14.  Unit cost for fertilizing:  Since the soil at this hazardous
waste facility is quite poor, fertilization is necessary.  Type 10/6/4
fertilizer costing $0.12 per Ib. (in 50-lb. bags) is applied at a rate
of 500 Ibs. per acre.  This corresponds to a nitrogen application rate
of 50 Ibs. per acre.  The unit cost of fertilizing is the sum of the
labor, materials and equipment costs.
         Labor                      $69.10/acre
         Materials                  $60.00/acre

                                  9-129

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         Equipment                  $ 5.00/acre
Previous experience at this facility has shown that this application
rate for fertilizer is satisfactory.
     15. Unit cost for mulching with straw:  Since the soil is bare,
protection from erosion must be provided while the grass starts to grow.
This is achieved by using straw mulch at an application rate of 1 ton
per acre.  The unit cost of mulching is the sum of the labor, materials
and equipment cos ts.
         Labor                      $34.50/acre
         Materials                  $85.00/acre
         Equipment                  $ 5.00/acre
     16. Total unit replanting cost (Line 13 + Line 14 + Line 15):  The
total unit replanting cost is the sum of the seeding, fertilizing, and
mulching costs.  Lime is not applied at this facility because it  is not
recommended by the Agricultural Extension Service (USDA).
     17. Total replanting costs (Line 4 x Line 16):  The total replanting
costs for the entire 30-year period are then $20,796.
     18. Total costs for initial replanting to establish vegetation (Line
12 + Line 17):  The total costs for the initial replanting to establish
vegetation are then $20,847.
     19. Total annual cost (Line 18 4- 30):  The total cost for the initial
replanting to establish vegetation is divided by the 30 years of  the post-
closure period to yield the total annual cost, for a total of $695.

E.   Administrative Services
     1.  Number of technical hours required for administrative duties
(annual):  Since the facility is closed, all of the required administration
is an extra cost that must be carefully accounted for.  This facility esti-
mates that an average of three weeks of labor by a manager is required  to
administer the complete set of specified post-closure activities.  This
average administrative requirement includes the administration of the
occasional contingent events described in Worksheet C.
     2.  Person-hour cost for technical administrative duties:  The labor
rate for facility technical labor is $30 per hour fully-loaded.
     3.  Total administrative costs for technical labor (Line 1 x Line  2) :

                                   9-130

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The total cost for administrative technical labor is the product of the
hours required and the labor rate.
     4.  Number of clerical hours required for administrative duties:
Three weeks of clerical work is required to support the technical adminis-
trator .
     5.  Person-hour costs for clerical administrative duties:  The fully-
loaded labor rate for clerical labor at the facility is $8 per hour.
     6.  Total administrative costs for clerical labor (Line 4 x Line 5):
The total cost for administrative clerical labor is the product of the
hours required and the labor rate.
     7.  Office or trailer rental:  The total annual administrative cost
also includes the rental of office space during the busier times of each
post-closure year.  This includes typewriter,- telephone and supplies.
     8.  Total annual administrative costs for post-closure activities
(Line 3 + Line 6 + Line 7):  The total cost of administration is the
sum.of the costs of technical labor, clerical labor, and office rental.

F.   Total Costs Including Administration and Contingencies
     Items 1 through 5 summarize the total annual costs of the post-
closure functions taken from the cost worksheets.  The erosion contingency
repair cost (Line 3) used is the annual cost of the two major erosion
events expected in the post-closure period (30 years).
     6.  Total of Lines 1 through 5:  The total costs of the activities
listed in Lines 1 through 5 are $40,206.
     7.  Contingencies:  Fifteen percent of the sum of the above costs is
taken as an allowance for contingencies.  This contingency allowance is
made in addition to the costs expected from the two major post-closure
erosion events.
     8.  Administration:  An additional 10 percent of Line 6 is included
for fees, insurance and related needs.
     9.  Total annual costs of post-closure (Line 6 + Line 7 + Line 8):
The total sum of the annual post-closure costs is $50,258.
                                  9-131

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                               POST-CLOSURE
                WORKSHEET A - PERIODIC FACILITY INSPECTION
 1.   Number of technical management person-hours              16 hours
      required for each routine inspection of the
      closed facility
 2.   Annual number of routine inspections                     6
 3.   Person-hour costs for technical management labor         $30
 4.   Technical labor costs for annual routine inspections     $2880
      (Line 1 x Line 2 x Line 3)
 5.   Annual number of engineer-supported inspections          2
 6.   Number of independent state-certified engineering        8 hours
      hours for each engineer-supported inspection
 7.   Number of technical management hours for each            8 hours
      engineer-supported inspection
 8.   Person-hour cost for a professional engineer             $75
 9.   Engineering labor costs for the engineer-supported       $1200
      inspections (Line 5 x Line 6 x Line 8)
10.   Technical labor costs for the engineer-supported         $480
      inspections (Line 3 x Line 5 x Line 7)
11.   Labor costs for the engineer-supported inspections       $1680
      (Line 9 + Line 10)
12.   Truck rental cost for each inspection                    $36
13.   Annual truck rental cost for inspections                 $288
      (Line 2 + Line 5 x Line 12)
14.   Total annual inspection cost (Line 4 + Line 11 +         $4848
      Line 13)
                                   9-132

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                               POST-CLOSURE
        WORKSHEET B - ROUTINE MONITORING AND MAINTENANCE ACTIVITIES
 Mowing Operations
 1.   Facility acreage
 2.   Mowing labor (per acre)
 3.   Mowing equipment (per acre)
 4.   Unit mowing cost (Line 2 + Line 3)
 5.   Annual frequency of mowing
 6.   Annual cost of mowing (Line 1 x Line 4 x Line 5)
 Routine Erosion Damage Repair
 7.   Annual routine erosion rate
 8.   Total annual routine erosive loss  (Line 1 x Line 7)
 9.   Unit cost for hand excavation of soil
10.   Unit cost for transporting of soil on-site
11.   Unit cost for hand compacting soil (repairing
      erosive damage)
12.   Unit cost of seeding
13.   Aggregate unit cost of repairing routine soil
      erosion damage (Line 9 -I- Line 10 + Line 11 4- Line 12)
14.   Total annual cost for repairing erosive damage of
      a routine nature (Line 8 x Line 13)
15.   Adjustment factor to account for unusually wet seasons
16.   Annual cost for repairing routine erosive damage
      (Line 14 x Line 15)
 Fence Replacement
17.   Frequency of replacing fence

18.   Facility perimeter
19.   Unit cost of replacing fence
200 acres
$14.28
$5.37
$19.65
Once a year
$3930

0.12 tons
per acre
(.089 cu.
yds./acre)
17.8 cu. yds.
$21.21/cu. yd.
$2.13/cu. yd.
$21.21/cu. yd.

$l/cu. yd.
$45.55/cu. yd.

$810.79
$1621.58
Once during
post-closure
period
11,808 ft.
$13.06/linear
ft. (installed)
                                    9-133

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WORKSHEET B (continued)
20.  Total cost of fence replacement (Line 18 x Line 19)
21.  Pro-rated annual cost of fence replacement
Fertilizing
22.  Unit cost for fertilizing
23.  Number of fertilizer applications for first 3 years
24.  Number of fertilizer applications during remainder
     of post-closure (Years 4-30)
25.  Total costs of fertilizing for first 3 years
     (Line 1 x Line 22 x Line 23)
26.  Total costs of fertilizing for post-closure
     years 4-30 (Line 1 x Line 22 x Line 24)
27.  Total fertilizing costs (Line 25 + Line 26)
28.  Annual cost of facility fertilization (Line 27 4- 30)
Ground^water Monitoring Well Replacement
29.  Unit cost for replacing well
30.  Number of wells needing replacement during the
     post-closure period
31.  Total cost of monitoring well replacement during
     the entire post-closure period (Line 29 x Line 30)
Leachate Pumping and Disposal
32.  Frequency of removing the leachates
33.  Average monthly total leachate withdrawal
34.  Unit cost of removing the leachate to an active
     off-site TSDF
35.  Total annual cost of removing leachate
     (Line 32 x Line 33 x Line 34 x 12)
36.  Unit cost for disposing of leachate off-site (at
     a surface impoundment)
37.  Annual costs for disposing off-site (Line 32 x
     Line 33 x Line 36 x 12)
38.  Total annual costs for removing and disposing of
     leachates (Line 35 + Line 37)
$154,212.48
$  5,140.41

$134.10/acre
    3
    5

$ 80,460

$134,100

$214,560
$  7,152

$425/well
2

$850


Once/month
2000 gals.
$0.18/gal.

$4320

$.05/gal.

$1200

$5520
                                   9-134

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WORKSHEET B (continued)

Ground-Water Monitoring
39.  Number of wells monitored                             12 wells
40.  Number of samples taken per well (annual)             2 samples
41.  Total number of samples per well (annual)             24 samples
     (Line 39 x Line 40)
42.  Number of hours for collecting the samples (per       2 hours
     sample)
43.  Total number of hours for collecting samples          48 hours
     (Line 41 x Line 42)
44.  Total number of hours for preparing and delivering    6 hours
     samples
45.  Total sample handling hours (Line 43 + Line 44)       54 hours
46.  Person-hour costs for handling ground-water samples   $15
47.  Total sample handling costs (Line 45 x Line 46)       $810
48.  Unit cost of ground-water quality analysis            $77
49.  Unit cost of ground-water contamination analysis      $108
50,  Total cost for ground-water quality analysis          $924
     (annual) (Line 39 x Line 48)
51.  Total cost for ground-water contamination analysis    $2592
     (annual) (Line 41 x Line 48)
52.  Total annual ground-water monitoring cost (Line 49    $4326
     + Line 50 + Line 51)
Routine Maintenance Summation
53.  Annual mowing cost (Line 6)                           $3930
54.  Annual cost for repairing routine erosive             $1621.58
     damage (Line 16)
55.  Annual cost for replacing fence (Line 21)             $5140.41
56.  Annual cost for fertilizing (Line 28)                 $7152
57.  Annual cost for replacing well (Line 21 4- 30)         $28
58.  Annual cost for removing leachates (Line 38)          $5520
59.  Annual cost for ground-water monitoring (Line 52)     $4326
60.  Total annual cost for routine activities              $27.717.99
                                   9-135

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                                POST-CLOSURE
             WORKSHEET C - EROSION DAMAGE CONTINGENCY SCENARIO
 1.
 2.
 3.
 4.

 5.
 6.


 7.

 8.

 9.

10.

11.
12.
13.
14.
15.
16.
17.

18.

19.
Percentage of vegetation removed
Facility acreage
Acreage reduced to bare soil (Line 1 x Line 2)
Annual per acre soil loss rate (without
vegatative cover)
Monthly bare ground soil loss rate
Amount of soil lost before repairs are instituted
(Line 3 x Line 5x2) (The factor of 2 adjusts for
immediate soil losses)
Unit cost for excavating and loading soil (on-site
operations using a 2-cu. yd. front end loader)
On-site haul of excavated soil to area needing
repair
Filling and compacting the eroded areas (using
a dozer)
Total unit cost for soil replacement
(Line 7 + Line 8 + Line 9)
Cost of replacing lost soil (Line 6 x Line 10)
Unit cost for seeding the bare soil
Unit cost for fertilizing
Unit cost for mulching with straw
Total unit replanting cost (Line 12 + Line 13 + Line 14)
Total replanting cost (Line 3 x Line 15)
Number of erosive incidents expected in the post-
closure period
Total cost for repairing damage from erosive
incidents (Line 11 + Line 16 x Line 17
Total annual cost for repairs required by erosive
incidents (Line 18 4- 30)
30%
200 acres
60 acres
12 tons
per acre
1 ton per
acre
(.741 cu.
yds./acre)
120 tons
(89 cu. yds.)

$0.21 per
cu. yd.
$0.85 per
cu. yd.
$1.25 per
cu. yd.
$2.31 per
cu. yd.
$205.59
$88/acre
$134/acre
$124.50/ac.re
$346.50/acre
$20,790
2

$41,580

$1386
                                    9-136

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                                POST-CLOSURE
         WORKSHEET D - INITIAL REPLANTING TO ESTABLISH VEGETATION
 1.   Percentage failure of vegetation per year
 2.   Number of years required for full vegetation
 3.   Facility acreage
 4.   Total.acres to be replanted due to initial
      failure of vegetation (Line 1 x Line 2 x Line 3)
 5.   Annual per acre soil loss rate (for areas with
      inadequate vegetative cover)
 6.   Monthly bare ground soil loss rate

 7.   Amount of soil lost before repairs are
      instituted (Line 4 x Line 6)
 8.   Unit cost for soil excavation and loading
      (on-site operations using a 2-cu. yd. front end loader)
 9.   On-site haul of excavated soil to area needing
      repair
10.   Filling and compacting eroded areas (using a
      dozer)
11.   Total unit cost for soil replacement
      (Line 8 + Line 9 + Line 10)
12.   Cost of soil replacement (Line 7 x Line 11)
13.   Unit cost for seeding bare soil
14.   Unit cost for fertilizing
15.   Unit cost for mulching with straw
16.   Total unit replanting cost (Line 13 + Line 14 + Line 15)
17.   Total replanting costs (Line 4 x Line 16)
18.   Total costs for initial replanting to establish
      vegetation (Line 12 + Line 17)
19.   Total annual cost (Line 18 4- 30)
10 percent
3
200 acres
60

6 tons/acre

.5 tons
(.3706 cu.
yd./acre)
30 tons
(22 cu. yds.)
$0.21 per
cu. yd.
$0.85 per
cu. yd.
$1.25 per
cu. yd.
$2.31 per
cu. yd.
$50.82
$88/acre
$134.10/acre
$124.50/acre
$346.60/acre
$20,796
$20,847

$695
                                    9-137

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                               POST-CLOSURE
                  WORKSHEET E - ADMINISTRATIVE SERVICES
1.   Number of technical hours required for administrative    120 hours
     duties (annual)
2.   Person-hour cost for technical administrative duties     $30
3.   Total administrative costs for technical labor           $3600
     (Line 1 x Line 2)
4.   Number of clerical hours required for administrative     120 hours
     duties
5.   Person-hour costs for clerical administrative duties     $8
6.   Total administrative costs for clerical labor            $960
     (Line 4 x Line 5)
7.   Office or trailer rental (includes equipment and         $1000
     supplies)
8.   Total annual administrative costs for the post-closure   $5560
     activities (Line 3 + Line 6 + Line 7)
                                   9-138

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                                POST-CLOSURE
                   WORKSHEET F - TOTAL COSTS INCLUDING
                     ADMINISTRATION AND CONTINGENCIES
1.   Cost of inspections  (From Worksheet A)                     $  4,848
2.   Cost of routine monitoring and maintenance                 $27,718
     (From Worksheet B)
3.   Cost of contingency  erosion repairs (From Worksheet C)     $  1,386
4.   Cost of initial replanting to establish vegetation         $    695
     (From Worksheet D)
5.   Cost of post-closure administrative services               $  5,560
     (From Worksheet E)
6.   Total of Line 1 through Line 5                             $40,207
•
7.   Contingencies                                               $  6,031
8.   Administration, including fees, insurance, etc.            $  4,021
9.   Total annual costs of post-closure                         $50,259
     (Line 6 + Line 7 + Line 8)
                                                               Uo 1990
                                                               SW-913
                                   9—139      *U.S. GOVERNMENT PRINTING OFFICE: 1981 3*5-932/8290  1-3

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